HMRC sends pillar two educational letters to large businesses

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HMRC has started sending letters to large businesses who it believes may be within the scope of the UK’s new multinational top-up tax (MTT) and domestic top-up tax (DTT). The letters are intended to educate businesses about the new rules being introduced and allow them to clarify any issues in advance with HMRC.

MTT and DTT are the UK’s adoption of the pillar two global base erosion (GloBE) rules. The rules will apply for accounting periods beginning on or after 31 December 2023.

HMRC is writing to companies with:

a UK presence; and
that are members of consolidated groups with annual revenues of more than €750m in past accounting periods.

These companies may be required to register for the new taxes.

This educational campaign is being undertaken in two stages:

Customer compliance managers (CCMs) are being asked to share letters with businesses at a convenient time within a two-week period commencing 12 June.
For companies without a CCM, letters have begun to be issued this week.

HMRC is also writing to registered agents that it believes will have clients within the scope of MTT and DTT.

HMRC has set up a new pillar two compliance team. The team will work with the adviser community to help HMRC understand any problems that groups may have, and what action it can take to overcome them.

In addition, a dedicated mailbox has been established in relation to this activity: pillar2mailbox@hmrc.gov.uk. Businesses without a CCM can engage with HMRC using this email address if:

they want to receive future updates by email on pillar two developments, guidance, and event information – this may help their businesses prepare for the changes;
they are not sure whether they will be in scope of MTT and DTT and would like to discuss this with HMRC; or
their group has received this letter more than once – HMRC asks businesses to advise it of this so that it can update its records.

Copies of the three letters are:

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