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New rules for Pillar Two registrations

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HMRC have published a notice which explains how to register for Pillar Two top-up taxes in the UK (i.e. the domestic top-up tax and multinational top-up tax), the information required to complete such registrations and how to update HMRC with any relevant changes post-registration. The following sections of the notice have the force of law under authority in F(No. 2)A 2023 Sch 14:

  • 1.3 Who needs to register: i.e. groups with at least one entity located in the UK, and with consolidated annual revenues of €750m or more, noting that only the filing member for the group can use the online registration service.
  • 1.4 What you need to be able to register: this sets out the basic details to be provided to HMRC including names, addresses and company registration number for the filing member or ultimate parent entity.

Section 2 covers changes to registration details and requires HMRC to be notified within six months of a change to the filing member or to any of the details that were provided at registration.

The notice also includes a reminder that in-scope groups must register using HMRC’s online service within six months of the end date of the first accounting period in which the eligibility criteria were met.

In related news on Pillar Two, Guernsey has announced it ‘will shortly be lodging a policy letter proposing the introduction of an “Income Inclusion Rule” and a “Qualified Domestic Minimum Top-Up-Tax” to provide for a 15% effective tax rate for large in-scope multinational enterprises, from 2025.’

Ministers from Guernsey, the Isle of Man and Jersey met recently to discuss implementation of Pillar 2 on a common timeline ‘with introduction for accounting periods commencing on or after 1 January 2025’.

Issue: 1664
Categories: News