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Deadline to register for 15% Pillar 2 tax with HMRC looms

With the OECD’s Pillar 2 Global Minimum Tax now embedded in UK legislation, large multinational and domestic groups face a fast-approaching deadline: register with HMRC by 30 June 2025. The UK regime, comprising the Multinational Top-up Tax (MTT) and the Domestic Top-up Tax (DTT), applies to groups with consolidated annual revenues over €750 million in at least two of the previous four accounting periods.

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With the OECD’s Pillar 2 Global Minimum Tax now embedded in UK legislation, large multinational and domestic groups face a fast-approaching deadline: register with HMRC by 30 June 2025. The UK regime, comprising the Multinational Top-up Tax (MTT) and the Domestic Top-up Tax (DTT), applies to groups with consolidated annual revenues over €750 million in at least two of the previous four accounting periods.

Although no tax is payable on registration, all qualifying groups with at least one UK entity must register—even if their effective tax rate exceeds 15%. For most with a 31 December 2024 year-end, the deadline is six months later: 30 June 2025.

A single “filing member”—typically the ultimate parent entity, or optionally a UK-nominated entity—must register via HMRC’s online portal using a Government Gateway ID. Only the filing member can complete registration; agents are not permitted. Key information includes group structure, accounting periods, jurisdictional presence, and contact details.

After registration, groups must submit a GloBE Information Return within 18 months of the first accounting period end (15 months in subsequent years), alongside a UK self-assessment return for any MTT or DTT due.

While most small and medium (SM) UK groups fall outside the scope due to the high revenue threshold, those owned by larger multinational groups may still be affected. They could be required to register, support compliance, or become relevant in the group’s return. Additionally, SM groups contemplating expansion, acquisition, or international investment should consider future exposure and readiness.

Penalties for non-compliance apply under Schedule 41 of the Finance Act 2008. With June 2025 looming, even out-of-scope UK groups are advised to assess their position early, identify potential obligations, and prepare for an evolving global tax framework.

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