If you are the ultimate parent entity (UPE) of a group or a part of an overseas multinational (MNE) group within the scope of Pillar Two, you should be aware of an upcoming registration deadline. This deadline is crucial for groups with a 31 December 2024 year end, i.e., registration must be completed within six months of the end of the first accounting period starting on or after 31 December 2023, which is 30 June 2025 for in-scope MNE groups with an accounting period ending 31 December 2024.
The UPE is responsible for the registration but can nominate another entity (either in or outside the UK) as filing member its behalf. The filing member will be responsible for all Pillar Two compliance obligations of the group in the UK. Where the UPE nominates another group entity, the nomination should be documented in the company’s files, but it will not have to be submitted to HMRC. You can change the nominated filing member later by notifying HMRC in writing. There is potential benefit of choosing a UK entity as the filing member as that will enable HMRC to utilise central filing simplifications and share information that is filed with them with other tax authorities (potentially limiting the duplication of filing efforts by the group).
All that is needed to register is access to a government gateway ID (organisation ID and not an agent ID) and a password. To register, it will be necessary to provide:
Ross Robertson
BDO in United Kingdom
The UPE is responsible for the registration but can nominate another entity (either in or outside the UK) as filing member its behalf. The filing member will be responsible for all Pillar Two compliance obligations of the group in the UK. Where the UPE nominates another group entity, the nomination should be documented in the company’s files, but it will not have to be submitted to HMRC. You can change the nominated filing member later by notifying HMRC in writing. There is potential benefit of choosing a UK entity as the filing member as that will enable HMRC to utilise central filing simplifications and share information that is filed with them with other tax authorities (potentially limiting the duplication of filing efforts by the group).
All that is needed to register is access to a government gateway ID (organisation ID and not an agent ID) and a password. To register, it will be necessary to provide:
- Name and registered address for the UPE (meaning it will be necessary to identify who this is before registration). These details will also need to be provided for the filing member if it is not the UPE;
- Company registration number and unique taxpayer reference if the UPE or nominated filing member is a UK limited company or limited liability partnership;
- Whether the group being registered only has entities located in the UK, or in the UK and other jurisdictions;
- Start and end date of the group’s accounting period;
- Contact details and preferences for one or two individuals or teams in the group; and
- Contact postal address for the group
Ross Robertson
BDO in United Kingdom