Netherlands: Pillar Two tax return forms published
Published on April 23, 2026
The Dutch tax administration on April 23, 2026, published the forms to be used to comply with the three main obligations under the Pillar Two Minimum Tax Act in the Netherlands:
- Global anti-base erosion (GloBE) information return (GIR): The GIR xml schema has been made available and aligns with the GIR materials published by the OECD in January 2025. The GIR must be submitted by all Dutch constituent entities (CEs) or a Dutch designated filing entity (on behalf of all Dutch entities), unless it is filed in another jurisdiction and exchanged with the Netherlands (under DAC9 or the GIR MCAA). The GIR can be submitted via the portal “Digipoort” from June 1, 2026, and will be automatically exchanged with qualifying countries. The deadline for GIR filing is 15 months after the end of the fiscal year (18 months for the transitional year). Accordingly, calendar-year taxpayers will have their first filing obligation by June 30, 2026, in respect of the 2024 fiscal year.
- GIR notification: If the GIR is filed in another jurisdiction, a notification must be submitted to the Dutch tax authorities via an online form on the tax administration’s portal (available from June 2, 2026). Such notification is to be made within the same deadline as for the GIR.
- Local tax return for Pillar Two taxes: A single local tax return for IIR, UTPR and QDMTT has also been made available. The form can be submitted via the portal from June 1, 2026. The form is relatively short and does not require the disclosure of detailed IIR, UTPR, or QDMTT calculations. Instead, only general information (e.g., identification of group, UPE, GIR-filing entity, contact person) and a declaration of the amount of top-up tax payable is required. The deadline for both tax return and settlement of top-up tax liability is 17 months after the end of the reporting fiscal year (20 months for the transitional year). Accordingly, calendar-year taxpayers will have their first filing obligations by August 31, 2026, in respect of the 2024 fiscal year. For QDMTT and UTPR, there is a possibility to elect a Dutch designated entity to file and pay the tax on behalf of all Dutch CEs. No tax return will need to be filed in cases where no top-up tax is payable in the Netherlands.
Read a May 2026 report prepared by KPMG’s EU Tax Centre