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Pillar 2 - Postponement of the deadline for filing the returns related to the Qualified Domestic Minimum Top-up Tax and the top-up tax according to the qualified Income Inclusion Rule (IIR)

Date:

The law of 19 December 2023 (on the introduction of a minimum tax for multinational enterprise groups and large-scale domestic groups) imposes the obligation to file an annual return related to the Qualified Domestic Minimum Top-up Tax – QDMTT and the top-up tax according to the qualified Income Inclusion Rule (IIR).

1. Filing the returns related to the Qualified Domestic Minimum Top-up Tax – QDMTT

The aforementioned law of 19 December 2023 sets the deadline for submitting this (these) return(s) on the last day of the eleventh month following the end of the fiscal year (see Article 52).

As for returns related to the QDMTT, the deadline of 17 November 2025 previously granted is extended. Now the deadline for filing the aforementioned returns concerning the fiscal years:

  • starting on or after 31 December 2023
  • and ending at the earliest on 1 January 2024 and at the latest on 30 September 2025

is extended till 30 September 2026 included.

2. Filing returns related to the top-up tax according to the IIR

As for the top-up tax according to the IIR, the aforementioned law of 19 December 2023 (Article 57/1 related to Article 57) sets the deadline for filing the returns as follows:

  • on the last day of the fifteenth month following the end of the fiscal year starting at the earliest on 1 January 2025
  • on the last day of the eighteenth month following the end of the fiscal year starting at the latest on 31 December 2024.

As for returns related to the top-up tax according to the IIR, the deadline for filing the returns related to the fiscal years:

  • starting at the earliest on 1 January 2025  
  • and ending at the latest on 31 May 2025

is extended till 30 September 2026 included.

As for returns related to the top-up tax according to the IIR, the deadline for filing the returns related to the fiscal years:

  • starting on 31 December 2023 and at the latest on 31 December 2024
  • and ending at the latest on 28 February 2025

is also extended till 30 September 2026 included.

This means that for the filing of all returns related to the QDMTT and the top-up tax according to the IIR whose filing deadline provided for by the law is set before 30 September 2026, an extension is granted till 30 September 2026 included.
 
We will provide you with practical guidelines and technical documentation concerning the filing procedure at a later date.

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