Under the updated framework, eligible multinational groups that centrally file their GIR in a participating jurisdiction and submit a timely Overseas Return Notification (ORN) will generally not be required to submit a separate UK GIR.
The UK’s His Majesty’s Revenue and Customs (HMRC) has updated its Pillar Two guidance to confirm the adoption of the OECD’s transitional approach for the central filing and exchange of the GloBE Information Return (GIR). Under the updated framework, eligible multinational groups that centrally file their GIR in a participating jurisdiction and submit a timely Overseas Return Notification (ORN) will generally not be required to submit a separate UK GIR.
Published on 29 July 2026, the revised guidance aligns the UK’s approach with the OECD’s transitional arrangements released earlier in 2026, providing greater clarity for groups facing their first Pillar Two reporting obligations. The measures also outline HMRC’s treatment of local filing requirements, deadlines, and penalties during the transition period.
Applicability
The transitional approach applies where the filing deadline for the GloBE Information Return (GIR) is no later than 31 December 2026. Where the GIR is centrally filed in one of the participating jurisdictions and HMRC receives the relevant GIR information from the overseas authority within six months of the filing deadline, HMRC will not enforce local filing of the GIR and will reduce certain penalties to nil.
To benefit from the arrangements, groups must submit an Overseas Return Notification (ORN) to HMRC on time. An ORN is regarded as submitted on time if it is filed before any late filing penalties arise, taking into account HMRC’s transitional approach to late filing penalties. The ORN must specify the date the GIR was filed overseas. However, where software issues prevent the GIR from being filed overseas before the ORN is due, the group should still submit the ORN on time using a notional GIR filing date of 1 January 2026.
Local filing switch off
HMRC said that where a GIR has been centrally filed in one of the participating jurisdictions and a timely ORN has been submitted, it will generally not require a separate information return to be filed in the UK.
The guidance notes that the UK’s GIR filing portal opened on 19 May 2026. HMRC has directed groups to its guidance on reporting Pillar Two Top-up Taxes and selecting appropriate software for submitting ORNs and GIRs.
Penalties
An ORN is valid only if, at the time it is submitted, the GIR has already been filed in an overseas jurisdiction that has an agreement with HMRC to exchange the information contained in the GIR. Ordinarily, submitting an invalid ORN would leave the group’s obligation to file a GIR in the UK unchanged, and failure to submit the return on time could result in late filing penalties.
However, because all participating jurisdictions have indicated their intention to enter into an agreement to exchange GIR information with HMRC, the authority said it will initially reduce the late filing penalty for the GIR to zero where a timely ORN names one of those jurisdictions.
Failure to receive the GIR on exchange
If HMRC does not receive the centrally filed GIR within six months of the filing deadline, it may contact the group to enforce the local filing requirement in the UK. In such cases, late filing penalties may begin to accrue until the group’s UK filing obligations have been met.
Central filing in the UK
The tax authority said businesses requiring information on submitting an ORN and GIR in the UK should refer to the How to report Pillar Two Top-up Taxes and Choose the right software for Pillar Two Top-up Taxes guidance pages.
Jurisdictions
The transitional approach applies where the GIR is centrally filed in any of the following jurisdictions:
Australia, Austria, Barbados, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Finland, France, Germany, Gibraltar, Greece, Hungary, Ireland, Italy, Japan, Liechtenstein, Luxembourg, Netherlands, Norway, Portugal, Republic of Korea, Romania, Spain, Sweden, Switzerland, Slovenia, South Africa and Turkey.
