Pillar 2 in the UK – FAQs on filing obligations

As multinational groups start to deal with the OECD’s pillar 2 rules, many are asking practical questions about UK filing requirements. This is especially common where groups already have pillar 2 processes in place in other countries.

This blog sets out the key FAQs we receive on UK pillar 2 registration. It focuses on what it means to appoint a filing member and what HMRC expects from that role. The FAQs below relate only to registering for pillar 2 in the UK, including who needs to register, the deadlines involved, ongoing responsibilities and the information required to complete the process. For a broader overview ahead of key compliance dates, read our related article on what you need to know before 30 June 2026.

Does the group need to register in the UK, even where an overseas parent entity is registering for pillar 2 in an overseas jurisdiction?

Yes. If your group is within the pillar 2 regime and has a subsidiary or permanent establishment in the UK, the group must register a “filing member”.

Does the filing member need to be UK resident?

No. The filing member is automatically deemed to be the ultimate parent entity, which does not need to be a UK resident. If a group wishes to elect for a UK resident company to be the filing member, the ultimate parent entity must nominate them in writing. The nomination doesn’t need to be submitted to HMRC but should be kept on file.

What is a filing member responsible for?

The company will be responsible for submitting the self-assessment return and the global information return (or overseas notification if it is filed in another jurisdiction). The filing member is also the main point of contact for HMRC correspondence regarding pillar 2 and is responsible for keeping records.

Even where no top-up tax is due, filing obligations still exist.

What is the deadline for registering for pillar 2 in the UK?

Groups must register the filing member no later than six months following the end of the first accounting period the group falls within the pillar 2 regime. The deadline is therefore 30 June 2025 for groups drawing up accounts to 31 December 2024.

Will the group need to register the filing member every year?

No. Provided the filing member remains the same, groups do not need to register every year. They only need to register in the first year the group falls within the scope of pillar 2.

Is the filing member responsible for paying the top-up tax?

No. The entity responsible for paying the multinational top-up tax will depend on the structure of the group and jurisdictions involved.

If top-up tax is due in the UK under the domestic qualifying top-up tax, it will be due from the entity which is liable under the calculation rules.

What information do I need to register a UK filing member?

• A UK government gateway log in. If one doesn’t exist for the filing member, a government gateway account must be created
• The name and registered address for the ultimate parent entity
• The name and registered address for the filing member, if it is not the ultimate filing entity
• If the filing member or the ultimate parent entity is a UK limited company or limited liability partnership, the company registration number (CRN) and unique taxpayer reference (UTR)
• Whether the group being registered only has entities located in the UK, or in the UK 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
• A contact postal address for the group

The registration essentially notifies HMRC which entity in the group will be responsible for filing in the UK. Therefore, information regarding all UK entities of the group is not required.

When are the first pillar 2 returns due?

The overseas return notification or the global information return and the UK self-assessment return for the period to 31 December 2024 must be filed by 30 June 2026. These returns must be filed using commercial software.

What information do I need to file a pillar 2 overseas return notification?

• Pillar 2 ID number received as part of the registration
• Accounting period start and end date
• The date the global information return was filed
• The country the global information return was filed
• The name of the entity which submitted the global information return
• The tax identification number of the entity filing the global information return

What information do I need to file a nil self-assessment return in the UK?

• Pillar 2 ID number received as part of the registration
• Accounting period start and end date
• Whether the return is in respect of the qualifying domestic top up tax or the multinational top up tax
• Whether the following elections have been made in relation to the UK:
  • Election for a wholly domestic group to use UK GAAP to calculate the domestic top-up tax in the UK
  • Election for a single member to be responsible for the pillar 2 tax liability