Portugal: Pillar Two notification form and instructions

The ordinance approving the notification form and the related instructions for Portuguese minimum taxation (Pillar Two) purposes was published in the Official Gazette on September 2, 2025, and came into effect the following day.

Key takeaways include:

• Under Portuguese minimum taxation law, each constituent entity located in Portugal and included in the scope of the Global Anti-Base Erosion (GloBE) Rules, must submit the notification form to the Portuguese tax authorities within nine months (12 months for the transitional year) after the end of the fiscal year in which the group falls within the scope of the GloBE Rules or when there are any changes in the elements contained in the notification. This means that, for calendar year taxpayers, the notification is due by December 31, 2025.
• The notification must be submitted by electronic means, on the specific Finance Portal of the Portuguese tax authorities.
• In case the notification is submitted by a designated local entity, each of the other entities of the group located in Portugal will be notified by electronic data transmission, to confirm the designation in the respective reserved area of the Finance Portal within 15 days from the date of notification.
• If the designation is not confirmed by one or more of the group entities located in Portugal, all group entities identified in the form are required to submit a new notification within 15 days from the date of initial notification.
• The notification remains valid for the subsequent fiscal years, unless changes occur within the group structure.
• In case of late or missing filing, penalties ranging between €5,000 and €100,000 may be imposed, together with a 5% daily penalty for each day of delay. Additionally, in cases of errors or omissions, penalties between €500 and €23,500 may apply, with relief available in the initial years subject to certain conditions. 

Read a September 2025 report prepared by KPMG’s EU Tax Centre