{{item.videoDuration}}
{{item.title}}
{{item.text}}
{{item.videoDuration}}
{{item.title}}
{{item.text}}
Countries begin to establish Pillar Two compliance procedures
May 2024
In brief
What happened?
Countries worldwide have begun enacting procedures that require in-scope groups and entities to register before making Pillar Two payments. Before filing a GloBE Information Return (GIR) or, if applicable, a Qualified Domestic Minimum Top-up Tax (QDMTT) return, certain countries have requested advance registration and assigned taxpayer identification numbers.
Why is it relevant?
Generally, a GIR and QDMTT return must be filed within 15 months of the end of the GloBE reporting year (extended to 18 months in the first fiscal year that the multinational company and large domestic group is within scope). However, there are local country exceptions to this general timing. In anticipation of these filings, countries have begun to enact internal procedures.
Action to consider
Taxpayers should be keenly aware of the varying Pillar Two registration deadlines. For example, those taxpayers who already are subject to Pillar Two in Belgium must register within 45 days of the ‘May 15th royal decree’ being published in the Belgian Official Gazette on May 29, 2024.
Belgium
Multinational companies and large domestic groups with a Belgian Constituent Entity need to file a notification at the Crossroads Bank for Enterprises regardless of whether the ultimate parent entity (UPE) is located in Belgium or another jurisdiction. In case of multiple Belgian entities, one Belgian entity should be appointed for the filing of the notification form on behalf of the Belgian affiliates.
Multinational companies and large domestic groups must submit a Pillar Two notification no later than 30 days after the start of the fiscal year for which the MNE or large domestic group enters the scope of Pillar Two. For those who already are subject to Pillar Two (e.g., since January 1, 2024), the first notification is required within 45 days of the ‘May 15th royal decree’ being published in the Belgian Official Gazette on May 29, 2024.
The notification includes:
- General group information, such as group name, fiscal year, address, etc.,
- Information on the type of consolidated financial statements,
- Detailed information regarding the ownership structure, including the entities that are an UPE, intermediate parent entity (IPE), partially-owned parent entity (POPE), and their subsidiaries, and
- Information on the group point of contact.
The notification to the Belgian Tax Authorities must be made via a standard form published in the Royal Decree, to be filed in XML format via the MyMinfin platform of the Belgian tax authorities. The group company number subsequently will be emailed to the designated group filing entity.
Register for PwC Belgium’s May 31st webcast to learn more about the registration and compliance.
United Kingdom
In-scope groups must register with HMRC within six months of the end of the first accounting period that started on or after December 31, 2023, that makes them subject to the rules. Groups that have entities located in the United Kingdom and other jurisdictions must register to report for both the Domestic Top-up Tax and the Multinational Top-up Tax (UK equivalent to an Income Inclusion Rule or IIR). Groups that only have entities located in the United Kingdom must register to report for Domestic Top-up Tax.
Only the filing member for the group can use the online service. This will be the UPE by default, but the UPE can nominate another group entity as the filing member. For example, for a US-parented MNE Group, another MNE Group entity can be nominated (e.g., UK, Dutch, Irish, etc. holding company), as the UPE would not have an in-force Pillar Two regime. The filing member does not need to be UK resident. However, if the filing member is not UK resident, it appears as though HMRC will not be able to automatically exchange any GIRs.
To register, the filing member will need to provide HMRC with:
- the name and registered address for the UPE,
- the name and registered address for the filing member, if it is not the UPE,
- if either of these are a UK limited company or limited liability partnership, the company registration number (CRN) and unique taxpayer reference (UTR) also must be provided,
- whether the group being registered only has entities located in the United Kingdom, or in the United Kingdom and other jurisdictions,
- the 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
- a contact postal address for the group.
If the filing member of the group changes after the group has registered, the new filing member must use the online service to update the group's filing member details. Groups have a legal requirement to replace their filing member's details within six months of the change occurring.
Ireland
Irish entities subject to Pillar Two must register with the Irish Revenue regarding each applicable tax (IIR, Undertaxed Profits Rule (UTPR), and Qualified Domestic Top-up Tax (QDTT)) within 12 months of the first fiscal year end in which the entity is subject to the tax.
The entities must provide the following:
- name and TIN of the entity,
- when relevant, the name, location, and TIN of its UPE and any designated filing entity,
- the tax(es) in respect of which the entity is registering,
- if the entity was appointed as the designated local entity, it must provide the names and TIN of itself and of other group members,
- information related to any group filing elections (QDTT or UTPR), and
- any other information as the Revenue Commissioners may reasonably require.
{{filterContent.facetedTitle}}
{{contentList.loadingText}}
{{contentList.loadingText}}
Contact us
Follow us
