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May 15, 2026

Article 13 of Decree-Law No. 157 of 2024 establishes a de minimis exclusion for the Qualified Domestic Minimum Top-Up Tax (QDMTT). The tax due on a taxpayer is reduced to zero for a tax period if one of two conditions is met. This occurs if the average total revenues of the group's taxable entities are less than €10 million, or if their average total net income is less than €1 million. The average is calculated over the current and two preceding tax periods. This provision explicitly does not apply to investment or stateless entities.

Chapter 3 - Tax Imposition and Entitlement

Article 13 - Minimum Revenue & Income

The tax due on a taxpayer shall be zero for any tax period in either of the following two cases:

The average total revenues of the taxable entities within a group, along with any adjustments made to them, are less than 10 million euros or its equivalent.
The average total net income of the taxable entities within a group is less than 1 million euros or its equivalent.

The average is calculated for the tax period in question and the two preceding periods. This provision does not apply to investment entities or stateless entities.