With the publication of the Ministerial Decree (DM) of 7 November 2025 a new tax return model has been introduced concerning the global minimum tax for large multinational and domestic groups with entities located in Italy.
Starting from financial years beginning on or after 31 December 2023, all entities belonging to groups that exceed the size thresholds set out in Article 10 of Legislative Decree No. 209/2023 are required to file a tax return.
Specifically, the Italian parent company, intermediate holding company, and partially owned subsidiary established in Italy—responsible for the supplementary minimum tax—are obliged to file.
The obligation also extends to entities responsible for the additional minimum tax, as well as companies, jointly controlled entities, and stateless entities established in Italy that are liable for the national minimum tax.