02/09/25
Ordinance 290/2025/1, of 2 September, published in the Official Gazette, approves Registration Form 62 and the respective instructions, for the purposes of the Portuguese Pillar Two Regime (“Regime do Imposto Mínimo Global” or “RIMG”), approved by Law no. 41/2024, of 8 november.
This form is intended for the fulfilment of the obligation to register constituent entities located in Portugal by enterprise groups subject to the aforementioned regime, as well as to notify the commencement of the regime’s application to large-scale domestic groups and multinational enterprise groups in the initial phase of international activity.
Form 62 must be submitted by the last day of the ninth month following the end of the fiscal year to which it relates or, in respect of the first fiscal year in which the group becomes subject to the RIMG, within 12 months after the end of that fiscal year.
Accordingly, for groups whose fiscal year coincides with the calendar year, the first Form 62, relating to the 2024 fiscal year, must be submitted by 31 December 2025.
The registration will remain valid for subsequent fiscal years until changes occur, for example, to the composition of the group, which will require the submission of a new registration for the relevant fiscal year in which such changes take place.
The form must be submitted by each constituent entity in Portugal or, alternatively, by a designated local entity, in which case the other group entities located in the country must confirm this designation electronically, via the Tax Authority Portal, within 15 days of notification for this purpose.
If the designation is not confirmed by one or more of the group entities within the specified period, all group entities must submit a new declaration within 15 days of notification for this purpose or, if later, by the end of the legal deadline for submission.
A registration submitted by a designated local entity will only be considered delivered on the date of the confirmation by the last group entity located in Portugal.
Under the RIMG, failure to submit or late submission of the newly approved declaration is punishable by a fine of € 5,000 to € 100,000, increased by 5% for each day of delay in fulfilling this obligation, whereas omissions or inaccuracies are punishable by a fine of € 500 to € 23,500. However, there is a specific provision for the possibility of exemption from fines in the first years of application of the regime, subject to certain conditions.
© 2025 PwC. This communication is of an informative nature and intended for general purposes only. It does not address any particular person or entity nor does it relate to any specific situation or circumstance. PricewaterhouseCoopers Tax Services TLS, Lda. We will not accept any responsibility arising from reliance on information hereby transmitted, which is not intended to be a substitute for specific professional business advice.