The UK HMRC released a notice regarding the registration process and basic guidance for Pillar 2 top-up taxes in the UK on Monday, 20 May, 2024.
Pillar 2 top-up taxes registration (notice 1)
The notice explains how to register for Pillar 2 top-up taxes in the UK, the information required to complete a registration and how to notify HMRC of any reporting related changes made after registration.
Overview
There are two Pillar 2 top-up taxes in the UK:
- Domestic Top-up Tax
- Multinational Top-up Tax
Groups must register with HMRC within six months of the end of the first accounting period that started on or after 31 December, 2023, which makes them subject to the rules.
Groups that have entities located in the UK and other jurisdictions must register to report for both Domestic Top-up Tax and Multinational Top-up Tax.
Groups that only have entities located in the UK must register to report for Domestic Top-up Tax.
Who needs to register
If you are a group or single entity who:
- Has at least one entity located in the UK.
- Has made consolidated group annual revenues of EUR 750 million or more within two of the last four accounting periods.
Then you must use the online service to register and report for Pillar 2 top-up taxes in the UK.
Only the filing member for the group can use the online service. This will be the ultimate parent entity (UPE) by default, but the UPE can nominate another group entity as the filing member.
The filing member does not need to be a UK resident. However, if the filing member is not a UK resident, HMRC will not be able to automatically exchange any Globe Information Return (GIR).
What you need to be able to register
To register, the filing member will need to provide HMRC with:
- The name and registered address for the UPE.
- The name and registered address for the filing member, if it is not the UPE.
- If either of these are a UK limited company or limited liability partnership, you must also provide the company registration number (CRN) and Unique Taxpayer Reference (UTR).
- Whether the group you are registering only has entities located in the UK, or in the UK and other jurisdictions.
- The start and end date of the group’s accounting period.
- Contact details and preferences, for one or two individuals or teams in the group.
- A contact postal address for the group.
Notifying HMRC about a change to the group’s filing member
If the filing member of the group changes after the group has registered, the new filing member must use the online service to update the group’s filing member details. Groups have a legal requirement to replace their filing member’s details within six months of the change occurring.
Changes to registration details
The filing member must use the online service to update any of the details provided at registration, within six months of the change occurring.
Registration deadline
Groups who meet the eligibility criteria must register using the online service within six months of the end date of the first accounting period in which the criteria were met.
