On 23 September 2026, the Portuguese Tax and Customs Authority (Autoridade Tributária e Aduaneira – AT) released the Model 64 – Settlement Declaration for the Global Minimum Tax (Imposto Mínimo Global – RIMG) applicable to the 2024 fiscal year. This declaration corresponds to the Top-up Tax calculation under the OECD Pillar Two framework, as transposed into Portuguese law by Decree-Law No. 64/2024. The form enables constituent entities of multinational enterprise (MNE) groups with annual revenues exceeding EUR 750 million to report and pay the complementary tax due in Portugal. The release follows the earlier availability of Model 62 (Registration) and Model 63 (GIR Information Declaration), completing the trilogy of compliance obligations for the first reporting cycle.
Key Takeaways
- Mandatory Filing for In-Scope MNEs: Portuguese resident constituent entities, or designated filing entities, must submit Model 64 electronically via the Portal das Finanças by the statutory deadline (typically 31 December 2026 for FY2024). The declaration computes the jurisdictional top-up tax based on the GloBE rules, including the substance-based income exclusion and qualifying domestic minimum top-up tax credits.
- Integration with Prior Obligations: Model 64 relies on data previously submitted via Model 63 (GIR Declaration) and the registration in Model 62. Taxpayers must ensure consistency across all three forms to avoid penalties. The AT has provided a detailed filling manual and validation rules to assist compliance.
- Payment and Penalties: The top-up tax assessed via Model 64 is payable upon submission. Late filing or inaccuracies attract penalties under the General Tax Law (Lei Geral Tributária), including interest on overdue amounts. Groups should coordinate with their tax advisors to finalize GloBE calculations and prepare for audit readiness.
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.
Source: Read Official Announcement