HMRC has confirmed it will temporarily waive late filing penalties for certain UK Pillar Two returns and notifications submitted before 1 August 2026, giving multinational groups additional time to meet their new compliance obligations during the transition to the global minimum tax regime.

UK’s tax authority, HMRC, has updated its Pillar Two guidance on 26 June 2026, confirming that under its transitional approach to implementing the Pillar Two top-up taxes, it will not impose late filing penalties for UK tax returns, overseas return notifications, or information returns submitted before 1 August 2026, even if they are filed after the statutory deadline.

HMRC has also published a paper outlining its transitional approach to the central filing and exchange of global information returns.

How to report Pillar Two Top-up Taxes

When to report

Once a group has registered to report Pillar Two Top-up Taxes, it must submit its UK tax return and information return on or before the deadline, unless the group meets the conditions for a below-threshold notification.

The deadline is 18 months after the end of the first accounting period. From the second period onwards, the submission deadline will be 15 months after the end of the accounting period.

An information return (also known as a GIR, or GloBE information return) is separate from the group’s UK tax return.

What happens if a group reports late

If a group does not submit its returns by the deadline, it may have to pay penalties. HMRC would usually apply late filing penalties for submissions of UK tax returns, overseas return notifications and information returns received after their due date.

However, under HMRC’s “transitional approach”, no late filing penalties will be charged if the submission is made before 1 August 2026.

What groups will need

Groups will need to have completed their registration for Pillar Two Top-up Taxes.

Groups will also need:

  • a Pillar Two ID (available on the confirmation page after registration)
  • access to compatible software that offers Pillar Two services

Groups should check the accounting period carefully before submitting. Once any submission has been made for an accounting period, that accounting period cannot be changed.

How to report

Groups must use compatible software to make Pillar Two Top-up Taxes submissions.

Groups must submit the UK tax return and one of the following by the submission due date:

  • information return
  • overseas return notification

The Pillar Two Top-up Taxes dashboard (accessed through the business tax account) will have details of due dates, and any returns overdue.

Below-threshold notification

From the Pillar Two dashboard, a below-threshold notification can be submitted if the group:

  • does not have consolidated annual revenues of EUR 750 million or more in at least 2 of the previous 4 accounting periods
  • is not expected to make consolidated annual revenues of EUR 750 million or more within the next 2 accounting periods

After returns have been submitted

HMRC will email groups when each return is received.

If the group sends an information return

HMRC will send a further email once the return has been processed. The email will confirm whether HMRC has accepted the return or whether any errors need to be fixed. If there are errors, the group must fix them and resend the return. If the return is resubmitted by 31 July 2026, HMRC will use the date the first information return was received as the submission date.

Global Information Return (GIR) Filing and Exchange: Transitional approach

The UK tax authority has confirmed it will not require dual filings of Global Information Returns for multinational groups that submit their tax documentation through participating overseas jurisdictions, a concession made in line with an OECD framework paper released on 18 May 2026.

The transitional arrangement covers groups with Pillar Two implementation deadlines up to 31 December 2026. Under the scheme, companies filing their GIR centrally in any of 31 named jurisdictions can avoid submitting a separate UK return, provided they meet two conditions: their overseas return notification (ORN) reaches HMRC on time, and the central authority shares the filing data with the UK within six months of the deadline.

What groups must do

Groups claiming relief must submit the ORN by the date penalties would normally apply, as set out in HMRC’s broader Pillar Two guidance. The notification must record the actual GIR filing date abroad—or, if software delays prevent overseas submission before the ORN is due, a notional date of 1 January 2026 can be used instead.

HMRC opened its own GIR filing portal on 19 May 2026 for companies choosing the UK as their central filing jurisdiction.

Penalty arrangements

Initially, HMRC will waive late filing penalties where an ORN is submitted on time, even if the overseas jurisdiction has not yet formalised information-sharing arrangements with the UK. However, the authority reserves the right to pursue penalties and require local UK filing if the centrally filed GIR is not received within six months of the filing deadline.

The relief applies to filings in Australia, Austria, Barbados, Belgium, Bulgaria, Canada, Croatia, Czechia, Denmark, Finland, France, Germany, Gibraltar, Hungary, Ireland, Italy, Japan, Liechtenstein, Luxembourg, the Netherlands, Norway, Portugal, South Korea, Romania, Spain, Sweden, Switzerland, Slovenia, South Africa, Turkey, and the UK itself.