HMRC released guidance on 19 May 2026 introducing a transitional approach to Global Information Return (GIR) filing and exchange under the OECD’s Pillar Two framework, including temporary relief from local filing requirements and late filing penalties in certain cases.
The UK’s His Majesty’s Revenue and Customs (HMRC) issued new guidance on 19 May 2026 outlining a transitional approach to Global Information Return (GIR) filing and exchange under the OECD’s Pillar Two framework. The guidance follows the common understanding on GIR filing published by the Organisation for Economic Co-operation and Development (OECD) on 18 May 2026.
Applicability
The transitional approach will apply where the filing deadline for the GIR is no later than 31 December 2026.
Where the GIR is centrally filed in one of the jurisdictions included in the Annex of the OECD paper, and HMRC receives the relevant GIR information from the other authority within six months of the filing deadline, the UK has decided that it will:
- not enforce local filing of the GIR
- reduce certain penalties to nil
To benefit from these arrangements, the group must also submit its overseas return notification (ORN) to HMRC on time.
Local filing switch-off
Where a GIR has been centrally filed by the filing deadline in any of the listed jurisdictions, and the ORN has been submitted on time, HMRC will generally not require an information return to be submitted in the UK.
Penalties
An ORN is only valid if, at the time it is submitted, the GIR has already been submitted to an overseas jurisdiction that has an agreement with HMRC to exchange GIR information.
Submitting an invalid ORN would normally lead to penalties. In such cases, the group’s obligation to submit a GIR locally in the UK would remain in place. Failure to submit a GIR on time could also trigger late filing penalties.
However, because all jurisdictions listed in the guidance have indicated an intention to enter into an exchange agreement with HMRC, the authority will initially reduce the late filing penalty for the GIR to zero where:
- an ORN naming one of those jurisdictions is submitted on time, and
- a GIR is filed in that jurisdiction by the UK filing deadline aligned with the OECD Model Rules
Failure to receive the GIR on exchange
If HMRC does not receive the centrally filed GIR within six months of the filing deadline, the authority may contact the group to enforce the local filing requirement and begin charging late filing penalties until the UK obligations are met.
Central filing in the UK
HMRC confirmed that the UK’s GIR filing portal opened on 19 May 2026.
Groups registered for Pillar Two Top-up Taxes must submit a UK tax return and information return by the applicable deadline unless they qualify for a Below-threshold notification.
The filing deadline is:
- 18 months after the end of the first accounting period
- 15 months after the end of subsequent accounting periods
The information return, also referred to as a GIR or GloBE information return, is separate from the UK tax return.
Late filing consequences
Failure to submit returns by the deadline may result in penalties under the Multinational Top-up Tax and Domestic Top-up Tax rules.
Filing requirements
Groups must complete registration for Pillar Two Top-up Taxes before filing.
The following are also required:
- a Pillar Two ID received after registration
- access to compatible software offering Pillar Two services
HMRC advised groups to check the accounting period carefully before submission, as the accounting period cannot be changed once a submission has been made.
How to report
Compatible software must be used for all Pillar Two Top-up Taxes submissions.
By the submission due date, groups must submit:
- a UK tax return, and
- either:
- an information return, or
- an overseas return notification
The Pillar Two Top-up Taxes dashboard, accessible through the business tax account, includes details of filing deadlines and overdue returns.
Below-threshold notification
A Below-threshold notification may be submitted where the group:
- did not have consolidated annual revenues of at least EUR 750 million in at least two of the previous four accounting periods, and
- is not expected to reach consolidated annual revenues of at least EUR 750 million within the next two accounting periods
After submission
After an information return is submitted, HMRC will issue an email confirming whether the return has been received and accepted.
Where the email identifies errors in the return, the software provider should be contacted.
Jurisdictions
The jurisdictions expected to be ready for central filing before 31 May 2026 are:
Australia, Austria, Barbados, Belgium, Bulgaria, Canada, Croatia, Czech Republic, Denmark, Finland, France, Germany, Gibraltar, Hungary, Ireland, Italy, Japan, Liechtenstein, Luxembourg, Netherlands, Norway, Portugal, Republic of Korea, Romania, Spain, Sweden, Switzerland, Slovenia, South Africa, Turkey and the United Kingdom.
Earlier, HMRC updated its guidance on “How to report Pillar Two Top-up Taxes” on 14 May 2026, adding details of a testing period for the new information return service ahead of its launch on 19 May 2026.
