Italy has introduced a central GloBE Information Return (GIR) filing mechanism under which a multinational group may file through a designated entity located in an exchanging jurisdiction, rather than requiring each Italian constituent entity to file locally. The critical condition is that the exchanged data must be received by Italian authorities by 31 December 2026; if that deadline is missed, Italian entities are required to file locally within one month. Groups operating in Italy should assess their filing chain now, before this exchange window closes.
Facts last verified: 22 September 2026.
Background: Pillar Two in Italy and the EU Framework
The Minimum Tax Directive (EU) 2022/2523 introduced the Global Anti-Base Erosion (GloBE) rules across EU member states, applying to multinational enterprise groups with consolidated annual revenue of EUR 750 million or more. Italy has transposed the Directive and is participating fully in the OECD/G20 Inclusive Framework.
On 5 January 2026, the OECD/G20 Inclusive Framework approved the Side-by-Side package, which addresses UPE safe harbours, further simplifications and the treatment of substance-based incentives. Commission Notice C/2026/253 of 12 January 2026 confirmed that the Side-by-Side package applies under the Directive. Groups with Italian constituent entities should ensure their GloBE computations and information returns reflect this updated framework, particularly where substance-based income exclusions are relied upon.
If your group is navigating the interaction between Pillar Two, existing tax structuring arrangements and Italian anti-avoidance rules, our team is available to assist. Please contact us at info@ferrazwhitmore.com or visit our contacts page.
Italy's Central GIR Filing Mechanism: The Key Rule
The Ministry of Economy and Finance (MEF) issued guidance on 22 June 2026 confirming that, for GloBE Information Returns relating to fiscal year 2024, central filing is permitted through a designated entity established in a jurisdiction that participates in the automatic exchange of GIR information with Italy. This approach aligns with the OECD's model for avoiding duplicative local filings across multiple jurisdictions.
The mechanism operates on a strict condition: if the relevant data are not received by Italian authorities by 31 December 2026, Italian constituent entities lose the benefit of central filing and must file locally, within one month of that deadline. This is not a soft administrative guideline – it is a hard trigger for local compliance obligations that affects every Italian entity within the group's structure, whether organised as an S.r.l., S.p.A. or otherwise.
Groups should also be aware that, on 11 September 2026, the OECD released an updated GIR template applicable to fiscal years beginning on or after 31 December 2025. Filings for FY2025 onwards will need to use this revised form.
Key Dates Tracker
| Item | Date or Status | Authority / Source |
|---|---|---|
| Italy: central GIR filing deadline (FY2024) | 30 June 2026 | MEF Guidance, 22 June 2026 |
| Italy: exchange condition – data must be received by Italian authorities | 31 December 2026 | MEF Guidance, 22 June 2026 |
| Italy: local filing deadline if exchange condition not met | Within one month after 31 December 2026 | MEF Guidance, 22 June 2026 |
| OECD Side-by-Side package approved | 5 January 2026 | OECD/G20 Inclusive Framework |
| Commission Notice C/2026/253 confirming Side-by-Side applicability under the Directive | 12 January 2026 | European Commission |
| General GIR deadline across most jurisdictions (FY2024) | 30 June 2026 | OECD / national implementations |
| France: extended GIR deadline (FY2024) | 1 September 2026 (announced 8 July 2026) | French tax authority |
| Portugal: GIR without penalties (FY2024) | Until 30 September 2026 – Order 76/2026-XXV, 3 June 2026 | Portuguese tax authority |
| Belgium: GIR notification deadline | 30 September 2026 | Belgian tax authority |
| OECD: updated GIR template released | 11 September 2026 (applicable to FY beginning on or after 31 Dec 2025) | OECD |
Practical Risks for Groups with Italian Entities
The 31 December 2026 exchange condition creates a narrow and non-extendable window. Several practical risks should be addressed before that date:
- Designated entity confirmation: The group must have formally designated an entity in a jurisdiction that is a recognised exchange partner of Italy. If the designated jurisdiction has not yet established a bilateral exchange arrangement with Italy, the central filing route is unavailable.
- Data completeness: Exchange of incomplete or rejected data may be treated as non-receipt for Italian purposes. Groups should verify that the information being submitted meets Italy's technical specifications under the MEF guidance.
- Overlap with transfer pricing documentation: Italian tax audit activity increasingly examines GloBE-relevant data alongside transfer pricing files held at the Registro delle Imprese and reported under Country-by-Country Reporting. Inconsistencies between these datasets attract scrutiny.
- Anti-avoidance interaction: Italy applies domestic anti-avoidance rules alongside Pillar Two. Where substance-based income exclusions are claimed under the Side-by-Side package, groups should document the underlying economic substance carefully to withstand a tax audit.
- Treaty considerations: Where a group relies on a tax treaty to mitigate top-up tax exposure, the interaction between treaty benefits and the income inclusion rule should be reviewed in light of the Side-by-Side guidance and current Italian administrative practice.
For groups that have already filed centrally – or are in the process of doing so – it is advisable to obtain written confirmation from the filing entity and, where possible, from the relevant competent authority, that the exchange to Italy has been successfully completed well before 31 December 2026. A missed exchange cannot be remedied retroactively; it triggers the local filing obligation automatically.
How This Compares with Other Jurisdictions
Italy's approach – permitting central filing subject to a hard exchange deadline – is broadly consistent with the OECD's recommended framework, but the 31 December 2026 cut-off is specific to Italy and does not carry over from the general 30 June 2026 GIR deadline used in most jurisdictions. By contrast, Portugal has extended its penalty-free window to 30 September 2026 (Order 76/2026-XXV), France to 1 September 2026, and Belgium has extended its GIR notification to 30 September 2026. None of these extensions alters Italy's own exchange condition.
Groups managing filings across multiple EU jurisdictions may find it useful to review how these timelines interact. Our alert on Cyprus Pillar Two and the Side-by-Side Decree provides a comparative perspective for groups with Cypriot holding structures.
Immediate Actions
Given the proximity of the 31 December 2026 exchange deadline, groups with Italian constituent entities should consider the following steps without delay:
- Confirm the designated filing entity and verify that its jurisdiction is an approved exchange partner of Italy under the current competent authority arrangement.
- Review the completeness of GloBE data already submitted or in preparation, cross-referencing against the updated OECD GIR template published on 11 September 2026.
- Assess whether any substance-based income exclusions claimed under the Side-by-Side package are supported by adequate documentation for Italian tax audit purposes.
- Establish an internal monitoring protocol to confirm receipt of exchanged data by Italian authorities ahead of 31 December 2026, with escalation procedures if confirmation is not obtained.
- Review the group's corporate structure in Italy to ensure that all constituent entities – including intermediate holding companies and operational S.r.l. entities – are correctly identified within the GloBE scope.
Tax risk management in this area requires close coordination between the group's central tax function, its Italian advisers and any designated filing entity. Ferraz & Whitmore advises international groups on Pillar Two compliance across European jurisdictions. To discuss your group's specific situation, please write to info@ferrazwhitmore.com or visit our contacts page.
Sources
- Irish Revenue – Pillar Two key dates: revenue.ie
- Regfollower – Italy updates Pillar Two guidance with GIR filing rules and FAQs: regfollower.com
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.