Global Daily Tax News, UK Releases New Pillar Two Administrative Guidance, (Nov 22, 2024)

On November 20, 2024, HM Revenue and Customs released new guidance on paying Domestic Top-Up Tax and Multinational Top-Up Tax and on replacing the filing member for purposes of Pillar Two top-up taxes.

The Pillar Two top-up tax payments guidance sets out deadlines for the payment of the two levies, as follows:

• June 30, 2026, if the first accounting period the group is required to report Pillar 2 Top-up Taxes ends on or before December 31, 2024;

• 18 months after the last day of the group's accounting period, if the first accounting period the group is required to report Pillar 2 top-up taxes ends after December 31, 2024;

• the later of June 30, 2026, and 15 months after the last day of the group's accounting period for all other periods.

It also sets out payment options and the account details for payments.

The guidance on replacing the filing member for a Pillar 2 top-up taxes account, meanwhile, explains who can replace a filing member and filing member responsibilities. It sets out how groups can replace the filing member in practice.