Pillar II registration in the UK

Why is it relevant?

On 20 May 2024, HMRC published practical guidance on Pillar II registration requirements for in-scope multinational groups operating in the UK. The registration must be done within six months of the end of the first accounting period. For companies with a 31 December year end, this means that the deadline for registration is 30 June 2025.

Who does it affect?

Pillar II affects multinational groups which have:

• at least one entity located in the UK; and
• consolidated group annual revenues of EUR 750 million or more, in at least two of the previous four accounting periods.

What do you need to know?

The guidance includes information on how to register for Pillar II Top-Up Taxes in the UK, the information required to complete a registration and how to notify HMRC of changes after registration.

Pillar II overview

There are two Pillar II top-up taxes in the UK:

• Domestic Top-up Tax
• Multinational Top-up Tax

Groups that have entities located in the UK and other jurisdictions must register to report for both Domestic Top-up Tax and Multinational Top-up Tax.
Groups that only have entities located in the UK must register to report for Domestic Top-up Tax.

Registration deadline

Groups must register with HMRC within six months of the end of the first accounting period that started on or after 31 December 2023 which makes them subject to the rules.
Registration must be done by the ‘filing member’, which will be the Ultimate Parent Entity (UPE) by default, but the UPE can nominate another group entity as the filing member. Registration is required, even if there is no UK liability.

What you need to be able to register

To register, the filing member will need to provide HMRC with:

• the name and registered address of the UPE
• the name and registered address for the filing member, if it is not the UPE
• if either of these are a UK limited company or limited liability partnership, you must also provide a 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

If a company fails to register, HMRC may charge penalties of up to 100% of the tax that ultimately falls due depending on whether the failure is deliberate and/or concealed. Further penalties may be charge for failure to make returns by the filing deadlines 9see below).

After registration

Once registration is complete, the filing member will be responsible for:

• notifying HMRC of any changes to the filing member;
• submitting the GloBE Information Return (GIR) or Overseas Return Notification (ORN) (due within 18 months of the end of the accounting period);
• submitting a UK Self Assessment return or Below Threshold Notification (BTN) (due within 18 months of the end of the accounting period);
• making or revoking elections; and
• ensuring the group keeps accurate records

What should you do next?

If you would like to discuss the above matter, or to confirm how this impacts your company, please get in touch with your usual Blick Rothenberg contact, or Andy Briggs using the details below or this form to see how we can assist with any future planning.