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:
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