Italy Approves Model for the GloBE Tax Return

On February 6, 2026, the Italian Revenue Agency approved the model for the GloBE Tax Return and provided instructions for its completion. This is a consolidated form with information on the calculation of top-up tax under the IIR, UTPR and QDMTT. 

Article 53(1) of Itay’s Pillar Two Decree requires submission of an additional self- assessment return (referred to as a ‘GloBE Top-Up Tax Return’) by the GIR filing deadline.

The previous Decree of November 7, 2025 provided for a single declaration form, consisting of two parts: (1) a general section, always mandatory, containing the data of the person submitting the declaration, information on the group, and any simplified or exclusion regimes that the group benefits; and (2) specific schedules for each of the three taxes (IIR, UTPR or QDMTT) for which the declarant is responsible (the schedules must be completed even if the tax due is zero).

The Model of the GloBE Tax Return approved in February 2026 follows this approach, with a general section and then 6 tables:

Table A -general information on the MNE or wholly domestic group as well as information on any safe harbours or exclusions applicable; 

Table B – data and information needed to determine the top-up tax;

Table C – data and information needed to determine the IIR top up tax

Table D – data and information needed to determine the UTPR top-up tax

Table E – data and information necessary to determine any QDMTT top-up tax

Table F – information on the top-up tax payable

Article 19 of the Pillar 2 decree requires the MNE group to identify the entity in Italy required to pay the UTPR. The filing obligation falls on this entity.  Article 18, paragraph 7, of the Pillar 2 Decree allows the group to designate one of the Italian entities to comply with the QDMTT declaration and payment obligation on behalf of the others. Tables D and E both require the designated entity to be indicated.  

The Tables above are to be completed on a jurisdictional/subgroup basis.

The GloBE Tax Return is required to be filed electronically via the software “Dichiarazione Globe” which will be available for download  from the Italian Revenue Agency’s website.  The date this is operational will be published by  a special notice published on the website.