Readers are reminded that groups within the scope of the Pillar Two rules in the UK must register within six months of the end of the first accounting period beginning on or after 31 December 2023. For impacted groups with a 31 December 2024 year end this means the deadline for registration is imminent – 30 June 2025.
Groups that need to register for Pillar Two top-up taxes (i.e. Domestic Top-up Tax and Multinational Top-up Tax) are those which have:
- At least one entity located in the UK; and
- Consolidated group annual revenues of 750 million euros or more, in at least two of the previous four accounting periods.
HMRC published a notice last year setting out how to register for Pillar Two top-up taxes in the UK, what needs to be provided, and how to notify HMRC of any reporting related changes. At the same time they also published a new online registration service which is accessed via the organisation’s Government Gateway user ID. Readers should be aware that the registration service cannot be accessed by agents so KPMG cannot complete the registration on behalf of clients.
Our KPMG Briefing Sheet explains how the registration process works and the information that the business needs to have available to complete it. Please speak to your usual KPMG in the UK contact or the authors if you would like to discuss any aspects of the registration process or the Pillar Two requirements more generally.