Dutch GIR Filing: A Practical Guide

Overview

The Dutch Pillar Two information return (bijheffing-informatieaangifte, ‘BIA’) is the Dutch implementation of the GloBE Information Return (‘GIR’). 

For in-scope groups with Dutch constituent entities, in-scope Dutch group entities must file a GIR/BIA for each fiscal year unless the GIR is filed in another jurisdiction and the Dutch Tax Administration receives it through international exchange. The normal GIR/BIA deadline is 15 months after the fiscal year-end; for the first fiscal year, the deadline is extended to 18 months. For a calendar-year 2024 first reporting year, this means a Dutch GIR/BIA or WMB notification deadline of 30 June 2026 (see the Dutch Tax Administration’s English-language minimum tax guidance).

The Netherlands uses the OECD/EU standard GIR template, but the filing is made through the Dutch digital infrastructure, Digipoort, and the XML should be prepared and tested against the current Dutch ODB BIA/GIR release package. The Dutch Tax Administration states that the GIR can be submitted from 1 June 2026 via Digipoort. See the Dutch Tax Administration’s minimum tax page.

A key practical distinction is between the GIR XML and the submission layer. The GIR itself is the OECD/EU-standard XML, subject to Dutch implementation specifications and validation. The Digipoort wrapper, WUS/SOAP envelope, signing, certificates, TLS, routing and status retrieval sit in the Digipoort connector or filing provider layer. Therefore, an MNE group preparing the XML normally should not be adding a separate Dutch wrapper inside the GIR XML. Direct submitters, however, must ensure that their Digipoort connection implements the required security and status processes. See Logius’s Digipoort connection guidance for businesses for more information.

The Three Main Dutch Pillar Two Returns/Notifications

There are three main separate Dutch Pillar Two Returns/Notifications:

GIR/BIA

The GIR/BIA is the information return. Dutch group entities subject to the regime must submit it annually unless it is submitted elsewhere and received in the Netherlands through international exchange. 

WMB notification

The WMB notification is relevant where the group files the GIR outside the Netherlands. In that case, ODB guidance says the group must notify the Dutch Tax Administration, specifying the group and identifying the entity filing the GIR on behalf of the group. If the group files the GIR in the Netherlands, no notification is required. ODB also states that login is possible with eHerkenning credentials. See ODB’s BIA information page.

Minimum tax return

The minimum tax return is the tax return required where top-up tax is payable in the Netherlands. This is separate from the GIR/BIA. The Dutch Tax Administration says the minimum tax return must be submitted within 17 months after the fiscal year-end, extended to 20 months for the first fiscal year, and can be submitted from 1 June 2026. 

Filing deadlines

For the GIR/BIA, the ordinary deadline is 15 months after the last day of the fiscal year. For the first fiscal year, the deadline is 18 months. The Dutch Tax Administration gives the following examples: for a 1 January 2024 to 31 December 2024 first fiscal year, the GIR/BIA and notification deadline is 30 June 2026; the tax return and payment deadline is 31 August 2026. For a 2025 calendar fiscal year, the GIR/BIA deadline is 31 March 2027 and the tax return/payment deadline is 31 May 2027. 

The same pattern applies to non-calendar years. For example, the Dutch Tax Administration gives a 1 October 2025 to 30 September 2026 first fiscal year as having a GIR/BIA or notification deadline of 31 March 2028, with the tax return and payment due by 31 May 2028. 

Filing channel: Digipoort

The Dutch GIR/BIA is submitted through Digipoort, the Dutch government digital messaging gateway. GIR submission is available from 1 June 2026.

The XML file is submitted through a Digipoort message process. ODB’s current BIA v11 release page says that delivery uses Digipoort Koppelvlak WUS, that Logius documentation describes how the Digipoort services are called, and that DAC9 validation results are returned via a status message. See the ODB BIA v11 documentation page.

For groups using a software vendor, managed filing platform, or intermediary, the Digipoort wrapper and security steps should be embedded in that submission process. For groups building a direct connection, those steps are a technical implementation obligation.

XML format