Pillar Two Reporting Netherlands: the GIR, Digipoort & 2026 Deadlines

Pillar Two reporting Netherlands is now live. Under the Dutch Minimum Tax Act 2024 (Wet minimumbelasting 2024), in-scope multinational enterprises must submit their first compliance filings, and for groups with a calendar-year 2024 financial year the first statutory window is open right now. The two dates that matter: 30 June 2026 (notification and GloBE Information Return) and 31 August 2026 (top-up tax return and payment, where due). This guide explains exactly what to file, where, and how Oakhill helps you stay compliant.

What is Pillar Two and the 15% minimum tax?

Pillar Two is the OECD’s global minimum tax: large groups must pay an effective tax rate (ETR) of at least 15% in every country where they operate, calculated on a jurisdictional blending basis.

Where the blended ETR in a jurisdiction falls below 15%, a “top-up tax” raises it to the minimum. The Netherlands implemented the rules through the Minimum Tax Act 2024, transposing the EU Pillar Two Directive and following the OECD GloBE Model Rules. It can be collected through a Qualified Domestic Minimum Top-up Tax (QDMTT), the Income Inclusion Rule (IIR) or the Undertaxed Profits Rule (UTPR).

Scope and thresholds: is your group in?

Pillar Two applies to multinational and large domestic groups with annual consolidated revenue of €750 million or more in at least two of the four preceding years.

Three points decide whether you have a Dutch obligation:

• Revenue limit. Consolidated group revenue of at least €750 million in two of the last four years.
• Entity impact. Every Dutch constituent entity is caught: subsidiaries, intermediate holding companies and permanent establishments, regardless of their standalone local revenue.
• Target rate. A 15% minimum ETR, calculated by blending all the group’s entities within a jurisdiction rather than entity by entity.

In short: if your global group is above the threshold and you have any presence in the Netherlands, you almost certainly have a Dutch filing obligation, even if the Dutch entity is small. Pillar Two draws on the same group data as country-by-country reporting, so groups already filing CbCR have a head start.

The three filing streams in the Netherlands

Dutch Pillar Two compliance is not one filing but three, each through a different Belastingdienst channel: the GIR, the notification, and the local top-up tax return.

1. The GloBE Information Return (GIR)

The GIR is the comprehensive, standardized international return capturing your group structure, GloBE calculations and ETR data. In the Netherlands it is submitted as an XML file via Digipoort, the government’s business digital gateway. For the 2024 transition year the deadline is 30 June 2026, extended from the standard 15 months to 18 months after year-end. Under the EU’s DAC9 directive a single GIR can be filed centrally in one jurisdiction and exchanged with the others, so a separate full Dutch filing may not be needed if it is filed abroad and exchanged.

2. The Pillar Two notification (kennisgeving)

The notification is a digital form identifying which group entity files the GIR and in which country, plus details of your entity, the group structure and the Ultimate Parent Entity (UPE). It is completed in the Gegevensportaal (Data Portal) using eHerkenning, and opens on 2 June 2026. Deadline: 30 June 2026. This step is easy to overlook because all attention tends to go to the return itself.

3. The local top-up tax return (bijheffing)

This is the formal Dutch return used to declare and pay any Qualified Domestic Minimum Top-up Tax (QDMTT) or Income Inclusion Rule (IIR) liability. It is filed through Mijn Belastingdienst Zakelijk. For the 2024 transition year the deadline is 31 August 2026 (extended to 20 months after year-end), and payment is due on the same day. Crucially, this return is only required if top-up tax is actually due, while the GIR and notification remain mandatory even if your ETR is well above 15% everywhere.

Key deadlines for fiscal year 2024

These extended dates (18 and 20 months) apply only to the first transition year. From the next year onward the GIR is due 15 months after year-end.

Key technical rules and safe harbours

Most groups will not run a full GloBE calculation for every country in the first years: the Transitional CbCR Safe Harbour can switch off the top-up tax for qualifying jurisdictions, but the GIR and notification still apply.

Transitional CbCR Safe Harbour

For the transition period, a jurisdiction can be treated as having no top-up tax if it passes one of three tests, based on qualifying country-by-country reporting and financial-accounting data: a de minimis test, a simplified ETR test, or a routine-profits test. This dramatically reduces the compliance burden for low-risk jurisdictions, but you still file the GIR and the notification. Whether you qualify depends on your CbCR data being “qualified”, which is exactly where many groups slip.

QDMTT accounting rules

The Dutch QDMTT requires calculations based on the local financial-accounting standard used for the group’s consolidation, for example Dutch GAAP or IFRS. Getting the accounting basis right is essential, because it drives the ETR and therefore whether top-up tax arises.

Substance-based carve-out (SBIE)

Taxable excess profit can be reduced by a substance-based income exclusion: a fixed return on eligible payroll costs and tangible assets in the jurisdiction. The percentages phase down over the transition period. For fiscal years beginning in 2026 they are approximately 9.4% on payroll and 7.4% on tangible assets (the 2024 year used higher rates, and both decline toward 5% over the coming years), so confirm the exact rate for your reporting year.

Recent legislation

The Dutch 2026 Tax Plan retroactively integrated outstanding OECD Administrative Guidance packages, adjusting technical interpretations and ensuring consistency across EU borders through DAC9 data exchange. Pillar Two is still moving, so interpretations and forms continue to be updated, which is one more reason to confirm the current position before filing.

Map your compliance workflow

Before you file, three questions shape your entire data and compliance workflow:

• Is your group headquartered inside the Netherlands or abroad? This determines whether the Dutch entity files the GIR or relies on a central filing exchanged under DAC9.
• Do you qualify for the Transitional CbCR Safe Harbour in your main jurisdictions? This decides how much full GloBE computation you actually need.
• What accounting standard does your Ultimate Parent Entity use (IFRS, US GAAP, Dutch GAAP)? This sets the basis for your ETR and QDMTT calculations.

Answer these three and the rest of the workflow falls into place. If you are not sure, that is precisely what our intake call covers.

Common pitfalls

• Assuming no filing is needed because the group is above 15% everywhere, when the GIR and notification still apply.
• Forgetting the notification in the Gegevensportaal because all focus went to the GIR.
• Leaving eHerkenning and Digipoort authorisations until the final week.
• Relying on CbCR data for the safe harbour that turns out not to be “qualified”.
• Unclear data ownership across multiple Dutch entities: decide early who is the designated filer.

How Oakhill helps

We take the Dutch minimum-tax obligations off your plate end to end: we confirm whether your Dutch entities are in scope, test your Transitional CbCR Safe Harbour position, handle the notification in the Data Portal, prepare and validate the GIR data and arrange the Digipoort XML submission, coordinating with your head office or central tax team where the GIR is filed abroad under DAC9. Where top-up tax is due, we prepare the QDMTT/IIR return and manage payment. Local, bilingual, and connected to your wider Dutch accounting and corporate tax compliance.

D.J. (Daniel) Thijs

Managing director, Oakhill Financial Services

Helps international groups set up and stay compliant in the Netherlands.

Related reading

Frequently asked questions

This article is general information about Dutch Pillar Two / minimum-tax reporting as of June 2026 and is not tax advice. Rules, rates and deadlines can change; please confirm your specific situation with a qualified adviser before filing.