Tax Insight

Italy approves Pillar Two annual declaration model

Insight
5 minute read
March 23, 2026

What happened?

With Measure No. 46523 dated February 6, 2026, the Director of the Italian Revenue Agency, approved the annual declaration model provided in Article 53 of Legislative Decree 209/2023. This relates to the top-up tax payable in Italy as Qualified Domestic Minimum Top-Up Tax (QDMTT), Income Inclusion Rule (IIR), or Undertaxed Profits Rule (UTPR), in accordance with paragraph 6 of Article 5 of the MEF Decree of November 7, 2025.

Why is it relevant?

This approval completes Italy’s operational framework for implementing the Pillar Two Global Minimum Tax for obligations due by June 30, 2026, for fiscal years ending December 31, 2024. It also finalizes Italy’s alignment with the OECD rules issued on December 14, 2021, and Directive (EU) 2022/2523, which set a 15% minimum tax rate for large multinational and domestic groups.

Pillar Two, and in particular QDMTT and IIR, applies to multinational or domestic groups that exceed the revenue threshold in Article 10 of Legislative Decree 209/2023, starting with fiscal years beginning on or after December 31, 2023. Subject to Article 57, UTPR under Articles 19, 20, and 21 generally applies from fiscal years beginning on or after December 31, 2024.

Actions to consider

In-scope multinational and domestic groups should promptly identify the entities responsible for filing each declaration type and assess the applicability of available safe harbor and simplified regimes to potentially reduce top-up tax liabilities. Even groups qualifying for safe harbor regimes are required to file the declaration. Companies should also ensure internal processes and data collection systems are in place to meet the upcoming filing and payment deadlines.