Italy Issues Decrees for Pillar Two Tax Return Filing and Payment

Italy has issued 2 regulations relating to the Administration of the Pillar 2 top-up tax. 

The November 7, 2025 Decree of the Deputy Minister of Economy and Finance provides for more information on the rules for the  submission of the GloBE tax return, and for the payment of top-up tax due in Italy.

Resolution no. 63 of November 10, 2025 provides for the tax codes to be used for the payment of top-up tax on the F24 payment form.

Filing

Article 53 of Italy’s Minimum Tax Law requires submission of an additional self- assessment return (a ‘GloBE Top-Up Tax Return’) by the GIR filing deadline (ie within 15 months of the end of the fiscal year – extended to 18 months in the transitional year).

The Decree of November 7, 2025 provides 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 Decree of November 7, 2025 provides that the IIR liability falls on the UPE, intermediate parent entity or the POPE located in Italy. ie the standard GloBE “top down” approach applies. eg , if the UPE is located in Italy, the IPEs are exempt from the filing obligation.

For the UTPR, under Art 19 of the Pillar 2 decree the MNE group is required to identify the entity in Italy required to pay the UTPR. The filing obligation falls on this entity. The distribution of the tax among entities located in Italy is then provided in the tax return.

For QDMTT purposes, Article 18, paragraph 7, of the Minimum Tax Law allows the group to designate one of the Italian entities to comply with the declaration and payment obligation on behalf of the others. The November 7, 2025 provides that the entity acting on behalf of other companies or JVs of the group, has the QDMTT filing obligation. The distribution of the tax among entities located in Italy is then provided in the tax return.

The amounts in the GloBE Tax Return must be provided in euros. Multinational groups must use the reporting currency of the group’s consolidated financial statements to perform all relevant calculations and to report the amounts. If the reporting currency of the consolidated financial statements is different from euros the exchange rate used is the the exchange rate on the last day of the financial year.

Payment

Article 53(2) of the Minimum Tax Act provides that 90% of the top-up tax is payable within 11 months after the end of the financial year. The remaining payment is made within 1 month of the deadline for filing the top-up tax return. Therefore, for the 2024 financial year coinciding with the calendar year, the first payment of 90% must be made by December 1, 2025 (as November 30 is a Sunday).

The second payment of the remaining 10%, must be paid within one month of the GIR filing deadline which would be the last day of July 2026 (as 2024 would be the transitional year).

Resolution No. 63 of November 10, 2025 provides that the Revenue Agency has established specific tax codes for payment on the F24 Payment Form. The code “2730” is for IIR tax, “2731” for the UTPR and code “2732” for the QDMTT. When filling in the payment form, these codes must be entered in the “Treasury” section, indicating the tax year to which the payment refers in the “YYYY” format. In addition, to distinguish the two instalments, the “instalment/Region/Province/month ref.” field must be completed in the “NNRR” format, where “NN” represents the number of the instalment (01 for the first, 02 for the second) and “RR” indicates the total number of instalments (which will always be 02).