Minimum Tax

On 31 December 2023, the Minimum Tax Act 2024 (GMT) came into effect. Profits of multinational and domestic groups with an annual turnover of at least €750 million are subject to a minimum tax rate of 15%.

The law applies to group entities of both multinational and domestic groups, based on the consolidated financial statements of the group's ultimate parent entity. Domestic groups are those where all entities are based in the Netherlands.

If a group falls within the scope of this law, it must assess whether the effective tax rate in each country where it operates is below 15%. If the effective tax rate in a country is lower, a top-up tax will be applied to cover the difference.

GloBE Information Return

Group entities based in the Netherlands and subject to this law must submit a GloBE Information Return (GIR) detailing the top-up tax for each fiscal year. This obligation does not apply if the GIR is submitted in another country and received by us through the international exchange of GloBE information.

The GIR must be submitted within 15 months after the last day of the fiscal year. For the first fiscal year, the deadline is extended to 18 months.

GIR submission is not yet possible

The OECD/EU has developed a standard template for the GIR, which the Netherlands will also use. Once submitted, the GIR will be automatically exchanged between tax authorities in different countries. The OECD will maintain a list of participating countries on its website. In the Netherlands, the GIR must be submitted via Digipoort.

Software development

Are you a software developer creating XML software for the GloBE Information Return (GIR), or is your company developing this in-house? You can register for specifications and support via Support Digital Messaging (SDM). For more information, visit the Support Digital Messaging (SDM) website.

Tax return

A group must submit a tax return if a top-up tax is payable in the Netherlands for the fiscal year.

  • The tax return must be submitted within 17 months after the end of the fiscal year.
  • For the first fiscal year, the deadline is extended to 20 months.

At present, it is not yet possible to submit a tax return via Mijn Belastingdienst Zakelijk. The tax return system is still under development.

Examples of submission deadlines

Example 1
Fiscal Year GloBE Information Return (GIR) & Notification Deadline Tax Return & Payment Deadline
1 January 2024 – 31 December 2024 30 June 2026 31 August 2026
1 January 2025 – 31 December 2025 31 March 2027 31 May 2027
Example 2
Fiscal Year GloBE Information Return (GIR) & Notification Deadline Tax Return & Payment Deadline
1 October 2025 – 30 September 2026 31 March 2028 31 May 2028
1 October 2026 – 30 September 2027 31 December 2028 28 February 2029

More information

Would you like to learn more about the Minimum Tax Act 2024 (GMT)? You can find more details in the Kennisdatabank Wet minimumbelasting (Database for the GMT). For further inquiries, contact pijler2@belastingdienst.nl.

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