Italy: Filing and payment obligations for Pillar Two top-up tax
Guidance under Ministerial Decree issued on November 7, 2025
A Ministerial Decree issued on November 7, 2025, established the filing and payment obligations for the Pillar Two top-up tax in Italy.
The decree confirms that the deadline for filing the Pillar Two tax return is the same as for the GloBE information return (GIR)—15 months after the fiscal year end or 18 months after the first fiscal year of application of the GloBE rules.
Read a November 2025 report prepared by the KPMG member firm in Italy