The Pillar II notification requirement applies more broadly than you might think, and the deadline is 30 June 2026.
The Minimum Tax Act 2024 (Pillar II) has been in force for over a year now. However, for many businesses, the practical implications are only just becoming real. From 2 June 2026 onwards, the Dutch Tax Authority will open the digital portal for the Pillar II notification (kennisgeving), a statutory reporting obligation that reaches further than most companies expect.
What is the Pillar II notification?
The Pillar II notification is not a tax return. Instead, it is a registration with the Dutch Tax Authority confirming that your entity belongs to a group within the scope of the Minimum Tax Act. Think of it as your entity’s formal introduction to the Dutch Tax Authority under the Pillar II framework. Submitted via the Dutch Data Portal using eHerkenning, the form asks for information about your entity, the group structure, the Ultimate Parent Entity (UPE) and the party that filed the Globe Information Return (GIR).
The point most people miss
The €750 million revenue threshold applies to the group as a whole, not to your Dutch entity individually. Therefore, if your entity is an intermediate holding company, a financing vehicle or a relatively modest subsidiary of a large international group, you may still be required to file a Pillar II notification, even if your own revenue is a fraction of that threshold.
This is the most underestimated risk of Pillar II: not the top-up tax itself, but the administrative obligations that apply to entities that consider themselves too small to have to do anything at all.
What are the risks of doing nothing?
Failing to file the Pillar II notification, or filing late, can result in penalties. But the signal it sends to the Dutch Tax Authority is at least as concerning: missing the notification implicitly suggests that your broader Pillar II position is not in order. That increases the likelihood of follow-up questions about the Globe Information Return, the application of safe harbour rules and profit allocation within the group.
Key deadlines
- 2 June 2026 for the opening of the Dutch Data Portal
- 30 June 2026 as the filing deadline for the Pillar II notification
- 31 August 2026 as the deadline for the Pillar II tax return and payment, but only where a top-up tax liability arises in the Netherlands
How we can help?
We support you with:
- assessing whether your Dutch entity is required to file a Pillar II notification,
- gathering the necessary group information (UPE, DFE, TIN numbers, GIR status),
- preparing and submitting the notification on time,
- aligning the notification with your broader Pillar II and GIR obligations.
Pillar II is complex, but this first step is manageable with the right guidance. Moreover, it is important not to wait until June, as gathering the required information takes considerably more time than completing the form itself. Do you have questions about your Pillar II notification obligation or the Minimum Tax Act more broadly? Get in touch with us.
