The UK HMRC released practical guidance on Pillar Two registration requirements for multinational groups in the UK on 20 May, 2024.
This guidance features a notice detailing the procedure for registering for Pillar Two Top-up Taxes in the UK. It also outlines the necessary information to be provided and the process for notifying HMRC of any reporting-related changes.
The registration requirements apply to the UK Domestic Top-up Tax (UK DTT) and the UK Multinational Top-up Tax (UK MTT).
Registration is necessary if a group has at least one entity in the UK and consolidated group annual revenues of EUR 750 million in at least two of the last four accounting periods.
Registration is mandatory even if no top-up taxes are owed.
If a ‘filing member’ meets the eligibility criteria, they must register using the online service within six months of the end date of the first accounting period in which the requirements were met. By default, the Ultimate Parent Entity (UPE) will be the filing member.
Required registration details
The filing member must provide HMRC with the following information:
- The name and registered address of the UPE (or filing member).
- The Company Registration Number (CRN) and Unique Taxpayer Reference (UTR).
- Confirmation of whether the registering group has entities located within the UK and/or abroad.
- The start and end dates of the group’s accounting period.
- Contact details for one or two individuals or teams within the group.
- The contact postal address for the group.
Submission of Top-Up Tax returns
Once a group has registered to report Pillar Two top-up taxes, they must submit their first returns no later than:
- 30 June, 2026, if the first accounting period for Pillar Two top-up taxes ended on or before 31 December 2024.
- 18 months after the last day of the group’s accounting period, if the first accounting period for Pillar Two top-up taxes ended after 31 December, 2024.
