Transitional Penalty Relief Regime

This is another temporary provision to relax penalties for MNEs in the initial years of the application of the GloBE Rules.
 
It applies for fiscal years beginning on or before December 31, 2026 but not after June 30, 2028, and provides that during this period, no penalties should apply relating to the filing of a GloBE Information Return where an MNE has taken “reasonable measures” to ensure the correct application of the GloBE Rules.
 
This will be at the discretion of tax authorities but the OECD notes that an MNE that can demonstrate that it has acted in good faith to understand and comply with the domestic application of the GloBE Rules and any QDMTT, this is likely to be viewed as taking reasonable measures.

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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. A November 7, 2025 Decree provides for more information on the rules for the submission of the GloBE tax return. 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.

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