Italy Pillar Two Filing Guide

-The annual Italian return is a domestic telematic declaration with a front page and Schedules A-F. 

-The DAC9/GIR information filing sits on a separate track and the Agenzia has published a dedicated XML/XSD package and presentation rules for it.

-For the first cycle, the main filing deadline cannot fall before 30 June 2026. The general rule is 15 months after year-end, with an 18-month window for the transitional first year.

-Italian Pillar Two tax is paid in two instalments: 90% by the end of the 11th month after year-end and the balance by the end of the month after the annual return deadline.

1) Overview of Italian Pillar Two Filing

2) Who files the annual Italian Globe tax return

Under the 7 November 2025 ministerial decree, the annual Italian declaration is filed by the Italian entities that are responsible for the relevant top-up tax stream. In broad terms, that means:

-the Italian ultimate parent, intermediate parent, or partially owned parent responsible for Italian IIR;

-the Italian entity designated to pay UTPR in Italy;

-the Italian joint venture entity or Italian stateless entity responsible for QDMTT/domestic minimum tax where the rules put the liability there; and

-excluded entities only where they have exercised an option that brings them into the filing perimeter.

3) The annual Dichiarazione fiscale Globe

The declaration approved on 6 February 2026 is built as a domestic Italian return with a general section and Schedules A-F. The published model and instruction snippets show the following structure:

The decree also makes clear that the annual declaration consists of a general section and schedules, and that UTPR and QDMTT schedules must identify the entities on whose behalf the filer is acting and how the amount is allocated among the relevant Italian entities.

Currency and calculation rules

Italian top-up taxes are determined under the Italian law, but the ministerial decree expressly says the annual return is completed in euro. Where the underlying GloBE computations are in another currency, the conversion is made using the exchange rate on the last day of the fiscal year.

Nil and no-tax cases

A common practical mistake is to treat the annual return as payment-only. The schedules relevant to the applicable regime still need to be completed even where the amount due is zero.

4) Filing mechanics for the annual return

Telematic filing only

The annual declaration is transmitted exclusively electronically, either by the taxpayer directly or through an authorised intermediary. Agenzia’s telematic services opened the dedicated filing service “Presentazione Dichiarazione fiscale Globe (DGL26)” on 31 March 2026.

Software stack

-DichiarazioneGlobe – the compilation software published by Agenzia, version 1.0.0 from 31 March 2026.

-Procedura di controllo – the control software, also version 1.0.0 from 31 March 2026.

-Desktop Telematico – the environment used to run the control procedure before transmission.

Replacement returns and annulments

The decree expressly allows a replacement return (dichiarazione sostitutiva) within the filing deadline. The technical material also indicates that the domestic annual return supports a full-annulment path that references the earlier telematic protocol number rather than re-populating all substantive schedules.

5) Italy-specific technical features for the annual GloBE return

The annual Dichiarazione fiscale Globe is not published as a simple OECD GIR envelope. Instead, the technical specifications approved on 8 April 2026 use the classic Agenzia domestic telematic approach with fixed record types and field-level validations.