The administrative provisions for the domestic top-up tax draw upon those enacted for the multinational top-up tax1. These are set out in detail in D4.307. Some modifications are necessary to deal with the fact that the qualifying entity for domestic top-up tax purposes may not be part of a group. This includes the definition of 'filing member'2, where references apply as if they were to the qualifying entity. References to 'multinational group' apply as if they were references to a group3.
HMRC online service
HMRC has confirmed it is developing a Pillar Two online service which will be introduced in phases. The first iteration was completed in May 2024, which included a registration facility for multinational top-up tax and domestic top-up tax purposes, which will then generate a Pillar Two reference number. The deadline to register is six months from the end of the accounting period in which the group became a qualifying group.
The next stage of the online service was completed in November 2024. The accompanying guidance sets out how
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Web page updated on 17 Mar 2025 17:34