UK registration for Pillar 2 compliance in the UK

As a reminder, Multinational enterprise (MNE) groups with annual revenue exceeding EUR 750 million in two of the last four fiscal years are in scope of the Pillar Two rules.

Pillar 2 registration in the UK will cover registration for multinational top-up tax (MTT) and the UK domestic top-up tax (DTT).  The same registration will cover both taxes.  Registration can only be done by the group itself (advisors cannot do this on your behalf), however, if you would like assistance with the registration process, please do not hesitate to contact us.

Some basic information on the process and some points you may need to consider are below.

Further information

1. UK registration portal

The entity/person that must register is the ultimate parent entity (UPE) by default, though another group entity can be nominated as the filing member.  If an entity other than the ultimate parent entity is to be the filing entity, it must be a company.

You will need the following information to complete the registration:

• the name and registered address for the UPE
• the name and registered address for the filing member, if it is not the UPE (it does not need to be UK resident. However. If the filing member is not UK resident the UK tax authorities may not be able to automatically exchange any Globe Information Return (GIR)). 
• if either of these are a UK limited company or a limited liability partnership, you must also provide the company registration number (CRN) and Unique Taxpayer Reference (UTR)
• whether the group you are registering only has entities located in the UK, or in the UK and other jurisdictions
• 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

2. Choosing which entity to register as the filing entity for UK purposes

It your group’s UPE is in a jurisdiction that is implementing Pillar 2 at a later date than the UK, the group will need to consider how it is going to meet its UK Pillar 2 filing obligations – and whether this will be through a UK group entity or a non-UK group entity. 

If your group’s UPE is located in a territory that is not implementing Pillar 2, your group will need to determine from which jurisdiction it plans to make its Pillar 2 filings and assess which group entity will make that filing.  Depending on the group’s situation, the UK may be one possible location from which to make filings.

3. Further factors to consider

There may well be options the group can consider to radically simplify its Pillar 2 compliance obligations.  These simplification options still require the ultimate filing of a Pillar 2 return (a GLoBE Information Return or GIR), but the data required to elect for the simplification options (transitional safe harbours) is likely to be easier to obtain than if the simplified arrangements are not available or not taken up.

The deadline for filing the first GIR in the UK is 18 months after the end of the accounting period for the first return, with a 15-month deadline applying for future years.  Thus, the first UK filing deadline for a group within scope for the year ended 31 December 2024 is 30 June 2026.

If you have not already started to consider how your group can collate the data and perform the calculations to populate a GIR, you should start this process as soon as possible.  Forvis Mazars does have a software solution that could help your group with its global Pillar 2 compliance.  We can provide more information and a demonstration of how it works.

In practice, determining relevant information can sometimes be complex due to the nature of the applicable rules. For any questions or assistance, a specialised team is at your disposal.