Pillar Two – Portugal releases official Form 64: Tax Assessment Return

In brief

Ordinance No. 318/2026/1, of 30 July, has been published, approving Form 64 Settlement Return and the corresponding completion instructions, under the Global Minimum Tax Regime (RIMG), approved by Law No. 41/2024, of 8 November. 

This return is intended to give effect to the provisions of Article 45(3) of the RIMG, with the purpose of determining the top-up tax due in Portugal by the constituent entities or by the designated local entity of the multinational enterprise group or large-scale domestic group. 

The approval of Form 64 represents a further step in the practical implementation of the Pillar Two Regime in Portugal, adding this filing obligation to the already existing Form 62 Registration Return and Form 63 Return (GIR).

In detail

Form 64 Return must be submitted electronically, through the Tax Authority Portal, by the constituent entities located in Portugal covered by the RIMG, or by the designated local entity, where this has been previously indicated and confirmed through the Form 62 Return. 

There is no obligation to file Form 64 where no top-up tax payable in Portugal is determined (that is, where the amount due is nil). 

It should be noted that the return requires identification of the return relating to the Pillar Two top-up tax of the Group (GIR), by indicating its respective number and filing date, which reinforces the importance, on a global scale, of coordinating and complying with the compliance obligations applicable to Groups covered by this Regime. 

^{© 2026 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.}