Italy · Pillar Two · In force

Italy Pillar Two obligations

Italy imposes 3 separate filing obligations under Pillar Two. The earliest is Modello di Notifica, due Same date as the Comunicazione rilevante — 15 months, 18 for the transitional exercise. Checked against the authority on 3 October 2026.

Checked 3 October 2026 Partly unverified 3 separate filing obligations

One unified annual return across all three charges, but payment runs on its own split schedule.

Italy also has obligations under e-invoicing. See the e-invoicing page →

Access gate — clear this before anything can be filed

Entratel / Fisconline abilitazione

Filing is through the Agenzia delle Entrate telematic services, directly or via an authorised intermediary under DPR 322/1998.

What is in force in Italy

Charge	Local name	In force from
IIR	Imposta minima integrativa	Exercises beginning on or after 31 Dec 2023
UTPR	Imposta minima suppletiva	Exercises beginning after 31 Dec 2024, subject to art. 57 exceptions
Domestic	Imposta minima nazionale	Exercises beginning on or after 31 Dec 2023

The 3 separate filing obligations

Modello di Notifica

Also: Notifica

Notifies the Agenzia delle Entrate that another group entity will file the Comunicazione rilevante.

Who files: Italian-located enterprises and Italian stateless entities that delegate filing
Deadline: Same date as the Comunicazione rilevante — 15 months, 18 for the transitional exercise
Channel: Entratel / Fisconline

Provvedimento prot. n. 321488 del 7 agosto 2025 — Agenzia delle Entrate ↗

Comunicazione Rilevante

Also: GIR

Italy's GloBE Information Return.

Who files: Each enterprise located in Italy and each Italian stateless entity in an in-scope group; may be filed by the controllante or a designated entity
Deadline: 15 months after the exercise end; 18 months for the transitional exercise. Not before 30 June 2026.
Channel: Entratel or Fisconline, XML per the published tracciato and XSD

Provvedimento prot. n. 112451 del 9 aprile 2026 — Agenzia delle Entrate ↗

Dichiarazione annuale (modello GLOBE)

Also: annual return

A single unified return covering imposta minima integrativa, suppletiva and nazionale.

Who files: Italian parent, intermediate and partly owned entities, and entities liable to the domestic charge
Deadline: 15 months after the exercise end; 18 months for the transitional exercise. Not before 30 June 2026.
Channel: Telematic to the Agenzia delle Entrate, directly or via a qualified intermediary

Provvedimento prot. n. 46523 del 6 febbraio 2026 — Agenzia delle Entrate ↗

Penalties

Referred to art. 51(9) D.Lgs. 209/2023. Amounts could not be verified from the primary text and are deliberately not stated here.

What catches groups out in Italy

Payment splits 90% by the 11th month after the exercise closes, with the 10% balance a month after the return deadline — earlier than most groups expect.
Separate F24 tax codes per charge: 2730 integrativa, 2731 suppletiva, 2732 nazionale. Offsetting against other credits is excluded.
Transitional simplified net-basis reporting is available for exercises ending before 1 July 2030.

Recent changes affecting Italy

2026-07-23 — Risoluzione 27/E introduces tax codes for ravvedimento of the information obligations.
2026-04-09 — Provvedimento 112451/2026 sets out how the Comunicazione rilevante is filed and publishes the XML tracciato and XSD.
2026-02-06 — Provvedimento 46523/2026 approves the unified annual declaration (modello GLOBE) covering all three Italian charges.

All dated changes →

Common questions

What must be filed in Italy under Pillar Two?

3 separate obligations: Modello di Notifica; Comunicazione Rilevante; Dichiarazione annuale (modello GLOBE).

When is the Modello di Notifica due in Italy?

Same date as the Comunicazione rilevante — 15 months, 18 for the transitional exercise. Filed by: Italian-located enterprises and Italian stateless entities that delegate filing. Channel: Entratel / Fisconline.

When is the Comunicazione Rilevante due in Italy?

15 months after the exercise end; 18 months for the transitional exercise. Not before 30 June 2026.. Filed by: Each enterprise located in Italy and each Italian stateless entity in an in-scope group; may be filed by the controllante or a designated entity. Channel: Entratel or Fisconline, XML per the published tracciato and XSD.

What access is needed before filing in Italy?

Entratel / Fisconline abilitazione. Filing is through the Agenzia delle Entrate telematic services, directly or via an authorised intermediary under DPR 322/1998.

What are the penalties in Italy?

Referred to art. 51(9) D.Lgs. 209/2023. Amounts could not be verified from the primary text and are deliberately not stated here.

Where this comes from

Every row on this page was checked against the authority's own published page on 3 October 2026. Decree and provvedimento references are correct, but Agenzia delle Entrate deep links could not be retrieved; the links point to the authority’s site rather than the specific page. Penalty amounts are not stated.

Cite this page

Saurabh Satija, “Italy Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-italy, accessed [date].

Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.

Other Pillar Two jurisdictions

United Kingdom · Ireland · Netherlands · Belgium · Germany · Spain · Luxembourg · Canada

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