Are you ready for Pillar Two? Essential Dutch filing deadlines for GIR and QDMTT

18 February 2026

As of 31 December 2023, the Pillar Two legislation in the Netherlands (“Wet Minimumbelasting 2024”) has entered into force. Pillar Two introduces a 15% global minimum tax for large multinational – and national - groups with annual consolidated revenues of at least EUR 750 million. Multinational enterprise (MNE) groups that fall within the scope of Pillar Two for financial years starting on or after this date must file a GloBE Information Return (GIR) and, where Dutch top‑up tax is due, a Qualified Domestic Minimum Top‑up Tax (QDMTT) return.

Designated Reporting Entity (DRE)

When the Ultimate Parent Entity will not file the GIR, the MNE group must appoint a Designated Reporting Entity to file the GIR on behalf of the group. The DRE should preferably be located in a jurisdiction that participates in the GloBE information‑exchange system (all EU Member States and, among others, Australia, Japan, South Korea, Norway, Switzerland, the UK).

If the DRE is located in a non‑exchange jurisdiction, the GIR will not be exchanged with the Netherlands. In that case, each Dutch entity must file its own local GIR.

GloBE Information Return (GIR) and GIR‑notification

If the GIR is filed outside the Netherlands by a DRE in an exchange jurisdiction, Dutch entities must file a GIR‑notification. Only one notification per group is required in the Netherlands.

If the GIR is filed locally in the Netherlands, or if the DRE is in a non‑exchange jurisdiction (triggering local GIR filings), no notification is required.

Qualified Domestic Minimum Top‑up Tax (QDMTT)

The Dutch QDMTT ensures that the Netherlands collects any top‑up tax due on low‑taxed Dutch entities before another jurisdiction can do so under the Pillar Two rules. If a Dutch entity falls below the 15% effective tax rate, a QDMTT return must be filed. Transitional safe harbours may postpone the need to file this return for financial years 2024–2026, but they do not affect the obligation to file the GIR or, where applicable, the GIR‑notification.

Deadlines Overview

Filing	Transition year deadline	Regular year deadline	Notes
GIR	30 June 2026	15 months after year-end	One GIR per group if DRE is in an exchange jurisdiction; otherwise each NL entity files locally.
GIR - notification	30 June 2026	15 months after year-end	Required only if GIR is filed abroad by a DRE in an exchange jurisdiction.
QDMTT Return	31 August 2026	17 months after year-end	Filing and payment share the same deadline.

Key takeaways

A GIR or GIR‑notification is always required, regardless of whether transitional safe harbours apply. We can support the full compliance cycle, from GIR (and GIR‑notification) through to the Dutch QDMTT return.
The preferable DRE should be tax resident in a jurisdiction that participates in the GloBE information‑exchange system. If you are considering where to locate the DRE to avoid multiple local GIR filings, we are ready to advise.
With our strong global Pillar Two network, we can coordinate and implement worldwide Pillar Two compliance, ensuring consistent reporting across all jurisdictions.

We’re ready to support you throughout your Pillar Two journey, from strategic decisions to hands‑on compliance. If you’d like to explore how we can help streamline your global Pillar Two obligations, we’re happy to discuss next steps.