The OECD’s Pillar 2 initiative introduces a global minimum tax of 15%, aiming to prevent base erosion and profit shifting by large multinational enterprise (MNE) groups. In the UK, the following two taxes were introduced for accounting periods beginning on or after 31 December 2023:
UK Pillar 2 obligations apply if your MNE group meets both of the following:
This applies regardless of:
Importantly, UK registration and filing obligations apply even if there is no UK top-up tax liability.
If the group is in scope, it must register with HMRC within six months of the end of the first relevant accounting period.
Examples:
| Year End | Registration Deadline |
|---|---|
| 31 December 2024 | 30 June 2025 |
| 31 March 2025 | 30 September 2025 |
| 30 September 2025 | 31 March 2026 |
The group must file:
Even if no tax is due, these filings are mandatory. The deadline for the first return is 18 months after the end of the accounting period.
Examples:
| Year End | Reporting Deadline |
|---|---|
| 31 December 2024 | 30 June 2026 |
| 31 March 2025 | 30 September 2026 |
| 30 September 2025 | 31 March 2027 |
The group must file:
Even if no tax is due, these filings are mandatory. The deadline for the first return is 18 months after the end of the accounting period.
Examples:
Transitional safe harbours allow simplified reporting in the initial years. On a jurisdiction-by-jurisdiction basis, a safe harbour is met if one of the following applies:
If you are subject to Country-by-Country (CbC) reporting, you are likely in scope.
Conduct an initial impact analysis to identify affected jurisdictions.
File the Pillar 2 registration with HMRC by the applicable deadline.
Organise internal systems and processes to support filing the GIR and Self-Assessment return.
We specialise in supporting multinational groups with UK subsidiaries or permanent establishments.
We can:
Your group must have consolidated revenue over €750 million in at least two of the previous four accounting periods.
Yes, registration and filing are mandatory even if no tax is due.
18 months after the end of the first in-scope accounting period.
Yes, if one of the three safe harbour tests is met. We can help determine eligibility.
Penalties apply for failure to register or submit required returns unless a reasonable excuse can be demonstrated.
Need help meeting your UK Pillar 2 obligations? Contact Türner & Co for expert support with registration, compliance, and reporting.
Managing Director
Senior Manager
Head of Direct Taxes
