The Portuguese Tax Authority has activated the electronic submission service for Model 63 — the Global Anti-Base Erosion (GloBE) Information Return (GIR) — under the Global Minimum Tax regime (Regime do Imposto Mínimo Global / Pilar 2), transposed via Decree-Law n.º 62/2024. This filing obligation applies to Ultimate Parent Entities (UPEs) of multinational enterprise (MNE) groups with consolidated revenues exceeding €750 million in at least two of the four preceding fiscal years. The portal-enabled service, available since early August 2026, supports the first reporting cycle for Fiscal Year 2024, with a deadline of 30 June 2026 (extended from 31 March via Despacho SEAF n.º 76/2026).
Key Takeaways
- Comprehensive Jurisdictional Data Required: Model 63 demands country-by-country reporting of GloBE income, covered taxes, substance-based income exclusion (SBIE), and top-up tax calculations per jurisdiction. Groups must reconcile this data with their Country-by-Country Report (CbCR) and financial statements.
- Integrated Validation Engine: The submission portal performs real-time cross-checks against the CbCR database, entity registry, and prior-year GIR data. Errors in EIN/TIN mapping, currency conversion rates, or SBIE thresholds will block submission until corrected.
- Filing on Behalf of Foreign UPEs Permitted: Portuguese-resident Constituent Entities may file a surrogate GIR if the UPE jurisdiction lacks a qualifying competent authority agreement. This prevents double filing and ensures Portugal collects its allocable share of any top-up tax.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
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