Pillar two is part of a package of measures agreed at OECD level by countries worldwide to tackle the challenges of taxing multinational enterprises. The UK’s pillar two taxes are the domestic top-up tax and the multinational top-up tax.
HMRC has published a notice explaining:
- how to register to report pillar two top-up taxes in the UK;
- the information required to complete a registration; and
- how to notify HMRC of changes after registration.
The notice contains tertiary legislation. Tertiary legislation carries ‘force of law’, meaning that it has the same legal status as primary and secondary legislation.
Groups within the scope of the rules must register with HMRC online within six months of the end of the first accounting period to begin on or after 31 December 2023. For example, the registration deadline is 30 June 2025 for an accounting period which began on 1 January 2024.
ICAEW has published a TAXguide explaining the pillar two top-up taxes.
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