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Three filings, three channels
The Dutch system splits Pillar Two compliance across separate portals.

• The BIA/GIR (bijheffing-informatieaangifte/GloBe Information Return) is the group-level information return, prepared using the OECD/EU standard template. It is filed via Digipoort (the Dutch government digital gateway) and becomes available from 1 June 2026.
• The Notification (kennisgeving) identifies the foreign filing entity and the relevant jurisdiction where the GIR is submitted abroad. It is submitted through the Gegevensportaal (Data Portal) and opens on 2 June 2026.
• The Dutch top-up tax return (belastingaangifte) is the formal return through which any top-up tax payable in the Netherlands is reported and settled. It is filed via Mijn Belastingdienst Zakelijk (My Tax Administration for Business) and becomes available from 1 June 2026.

Access to both the Notification form and the tax return requires eHerkenning, the Dutch business e-identification system.

How the obligations connect

A Dutch group entity within scope must submit a BIA/GIR for each fiscal year—unless the GIR is filed in another jurisdiction and exchanged with the Dutch tax administration through an international agreement. Where a GIR is filed abroad, the Dutch entity (or a designated local entity) must still notify the inspector which entity files the GIR and where.

The foreign filing route is only available if the filing jurisdiction is an EU Member State or has a qualifying competent authority agreement with the Netherlands. The OECD's GIR MCAA (Multilateral Competent Authority Agreement on the Exchange of GloBE Information) serves this purpose; the Netherlands signed it on 14 August 2025.

The Dutch top-up tax return is separate from the GIR. It must be filed when top-up tax is actually payable in the Netherlands. The amount is calculated from the international financial data in the GIR and formalised through this Dutch return.

First deadlines for calendar-year groups (FY 2024)

In principle, the GIR and the Notification must be submitted within 15 months after the end of the fiscal year, while the Dutch top-up tax return and the related payment are due within 17 months after year-end. A transitional rule extends the standard filing periods for the first reporting year:

• BIA/GIR or notification: 30 June 2026 (18 months after year-end)
• Dutch return and payment: 31 August 2026 (20 months after year-end)

For fiscal years ending before 31 March 2025, an additional rule applies: the BIA/notification cannot be due before 1 July 2026, and the return/payment cannot be due before 1 September 2026—relevant for non-calendar-year groups.

Questions on how this affects your group's Pillar Two position? Contact us to discuss your filing approach.