The Netherlands opens Pillar Two Filing from June 2026

The Dutch system is split across different channels. The BIA/GIR is filed through Digipoort (the government digital gateway). The notification is an online form in the Gegevensportaal (Data Portal), opening on 2 June 2026. The Dutch top-up tax return is filed through Mijn Belastingdienst Zakelijk (My Tax Administration for Businesses), which the main Belastingdienst site says will be available from 1 June 2026.

The June 2026 filing map

How the Dutch filing obligations fit together

Group entities located in the Netherlands that fall within scope must submit a BIA/GIR for each fiscal year, unless the GIR is filed in another jurisdiction and received by the Dutch tax administration through international exchange. Therefore, where a GIR is filed abroad, a Dutch group entity does not have to file a GIR in the Netherlands, but the Dutch entity (or a designated local entity acting for it) must notify the inspector which group entity files the GIR and in which state that entity is located.

The foreign filing route is available only where the filing occurs in an EU Member State or in a state that has a qualifying competent authority agreement between competent authorities) with the Netherlands. That is where the OECD exchange framework (and DAC9) becomes legally relevant. The GIR MCAA is expressly designed to serve as a qualifying competent authority agreement for GIR exchange, and the OECD’s signatory list shows that the Netherlands signed the GIR MCAA on 14 August 2025.

Separately, the Dutch top-up tax return should not be confused with the BIA/GIR. A group must file the Dutch return if top-up tax is payable in the Netherlands for the fiscal year. The GIR guidance manual adds that the Dutch amount of top-up tax is determined using the international financial data contained in the GIR and is then formalised through the Dutch return. 

Deadlines: ordinary rule and transitional rule

Outside the transition year, the GIR and notification are due within 15 months after the last day of the fiscal year, while the Dutch return and payment are due within 17 months after year-end. For the first fiscal year, those periods are extended to 18 months and 20 months respectively.

For a calendar-year group with a first reporting year running from 1 January 2024 to 31 December 2024, the the first filing dates are:

-BIA/GIR or notification: 30 June 2026;

-Dutch return and payment: 31 August 2026.

The BIA manual ties these timings to articles 13.1, 11.1 and 14.3 WMB 2024, and it also discusses article 14.4, a further transitional rule for fiscal years ending before 31 March 2025. This is relevant for non-calendar-year groups: the BIA/notification is not due before 1 July 2026 and the return/payment is not due before 1 September 2026.