HMRC has refreshed its guidance on registering and reporting Pillar 2 Top-up Taxes, clarifying who can file, what information is needed, and when returns are due.
UK HMRC updated their guidelines on “How to report Pillar 2 Top-up Taxes” and “Register to report Pillar 2 Top-up Taxes” yesterday, 1 September 2025.
Register to report Pillar 2 Top-up Taxes
Who can use the service
Only the filing member for the group can use this service.
The filing member will be either:
- The Ultimate Parent Entity
- Another company group member nominated by the Ultimate Parent Entity (for example, groups with an overseas Ultimate Parent Entity may want to nominate a UK group member to be the filing member)
The Ultimate Parent Entity is the entity at the top of the group ownership structure. It is not a subsidiary of any other entity.
HMRC will not ask for proof of this nomination during registration, but may ask for it during any compliance checks.
Who cannot use this service
Agents and tax advisers cannot register on a group’s behalf.
What you’ll need
To register, you’ll need to provide:
- The name and registered address for the Ultimate Parent Entity
- The name and registered address for the filing member (only if it is not the Ultimate Parent Entity registering)
You must also provide the company registration number, and Unique Taxpayer Reference if either of these are a:
- UK limited company
- limited liability partnership
You’ll also need to tell HMRC:
- Whether the group you are registering only has entities located in the UK, or in the UK and other jurisdictions, this decides whether you are registering for just Domestic Top-up Tax or also Multinational Top-up Tax as well
- 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
Register to report
To register to report Pillar 2 Top-up Taxes, you need to have an organisation’s Government Gateway user ID and password. If you do not have a user ID, you can create one the first time you register.
You cannot use an individual or agent Government Gateway user ID to register.
How to report Pillar 2 Top-up Taxes
When to report
Once your group has registered to report Pillar 2 Top-up Taxes, you’ll need to submit your returns on or before the deadlines. This 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.
What happens if you report late
If you do not submit your returns by the deadline, you may have to pay penalties. Read the Multinational Top-up Tax and Domestic Top-up Tax manual for more information.
What you will need
You will need to have completed your registration for Pillar 2 Top-up Taxes.
You will also need:
- Pillar 2 ID (you’ll get this on the confirmation page after you’ve registered)
- access to a third-party software that offers Pillar 2 services
How to report
You must use compatible software to make your Pillar 2 top-up taxes submissions.
HMRC is working with software developers to provide you with the ability to submit UK tax returns using suitable products. They’ll update the page when more information is available.
You must submit your UK tax return and one of the following by the submission due date:
- Information Return
- Overseas Return Notification
Your Pillar 2 Top-up Taxes dashboard (accessed through your business tax account) will have details of due dates and any returns overdue.
Below-Threshold Notification
From your Pillar 2 dashboard, you can submit a Below-Threshold Notification if the group:
- does not have consolidated annual revenues of EUR 750 million or more in at least two of the previous four accounting periods
- is not expected to make consolidated annual revenues of EUR 750 million or more within the next two accounting periods
After you’ve reported
