Statutory guidance

Notice 3 — Pillar 2 top-up taxes submission of returns

Published 30 June 2026

1. Overview

There are two Pillar 2 top-up taxes in the UK:

• Domestic Top-up Tax
• Multinational Top-up Tax

Once the conditions are met for a group to qualify for a Pillar 2 top-up tax, the filing member of a group must register with HMRC for the tax. The requirements on how to register are available at Pillar 2 top-up taxes registration (notice 1).

Once a filing member is registered it must submit a self-assessment return to HMRC for each accounting period, unless certain conditions are met. If the group is registered for both Pillar 2 top-up taxes only a single self-assessment return that contains information relating to both Pillar 2 top-up taxes is required.

If the group is no longer a qualifying multinational group, and it is unlikely to be a qualifying multinational group in the next two accounting periods, it may submit a notification (a below-threshold notification) of this to HMRC. Once it has done so it is no longer required to submit a self-assessment return while those conditions are still met.

A group that is a qualifying multinational group may submit a GloBE Information Return (GIR) with another authority that will send the relevant information from it to HMRC. If the group has filed the GIR in this way the filing member must supply a notification of this to HMRC (an ‘overseas return notification’ or ORN).

If the filing member does not submit an ORN it must submit an information return, this is also known as a GloBE Information Return or GIR.

1.1 Submission deadline

The self-assessment return or below threshold notification must be submitted to HMRC within 15 months of the end of the accounting period, unless it is the first accounting period the group is registered with HMRC when the deadline is 18 months after the end of the accounting period. The return does not need to be submitted before 30 June 2026, if this is later than the above dates.

If a group is required to submit an ORN to HMRC it must do so within 15 months of the end of the accounting period, unless it is the first accounting period the group is registered with HMRC when the deadline is 18 months after the end of the accounting period. The ORN does not need to be submitted before 30 June 2026, if this is later than the above dates.

If a qualifying group is not required to submit an ORN to HMRC it must submit an information return to HMRC within 15 months of the end of the accounting period, unless it is the first accounting period the group is registered with HMRC when the deadline is 18 months after the end of the accounting period. The information return does not need to be submitted before 30 June 2026, if this is later than the above dates.

If the filing member does not comply with these requirements, penalties may apply under the Pillar 2 top-up taxes legislation. Further details about the late penalties can be found in the Multinational Top-up Tax and Domestic Top-up Tax manual.

1.2 Amendment deadline

After a return or notice has been submitted it may be amended by the filing member. The filing member is not able to amend a return or notice after the end of 12 months following the day after the latest date by which the return or notice was required to be submitted.

2. Returns and notifications

2.1 Self-assessment return

2.1.1 Content of submission

This section has force of law for Multinational Top-up Tax purposes under paragraph 13(2)(b) of schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 13 of schedule 14 applies by virtue of paragraph 4 of schedule 18 to the Finance (No. 2) Act 2023.

The self-assessment return must contain, for each Pillar 2 top-up tax the group is registered for:

• the Pillar 2 reference for the group
• the start and end dates of the accounting period the return relates to
• the total amount of liability of the group to Pillar 2 top-up taxes, separately providing the liabilities of the IIR and UTPR components of the Multinational Top-up Tax as well as the Domestic Top-up Tax liability
• the full name, UK Unique Taxpayer Reference (UTR), or if a UTR is not available their Company Registration Number, and amount of liability for each member of the group liable to the Pillar 2 top-up taxes
• details of any election that is required to be included in the self-assessment return
• such further meta-data as specified in the submission format that is required to successfully submit the self-assessment return to HMRC’s systems

2.1.2 Method of submission

This section has force of law for Multinational Top-up Tax purposes under paragraph 13(6) of schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 13 of schedule 14 applies by virtue of paragraph 4 of schedule 18 to the Finance (No. 2) Act 2023.

The filing member for the group is required to submit the self-assessment return using software that is capable of providing all of the information and in the format as is required by this notice.

The self-assessment return must be provided in the format specified at Submit UK Tax Return: Pillar 2.

2.1.3 Amendment to the self-assessment return

This section has force of law for Multinational Top-up Tax purposes under paragraph 14(4) of Schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 14 of Schedule 14 applies by virtue of paragraph 4 of schedule 18 to the Finance (No. 2) Act 2023.

An amendment to a self-assessment return must be submitted using software that is capable of providing all of the information and in the format specified at Amend UK Tax Return: Pillar 2.

2.2 Below-threshold notification

2.2.1 Content of submission

This paragraph has force of law for Multinational Top-up Tax purposes under paragraph 13(7) of schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 13 of schedule 14 applies by virtue of paragraph 4 of schedule 18 to the Finance (No. 2) Act 2023.

To submit the below-threshold notification the filing member must supply HMRC with the start and end dates of the first accounting period that the below-threshold notification applies to.

2.2.2 Method of submission

This section has force of law for Multinational Top-up Tax purposes under paragraph 13(6) of schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 13 of schedule 14 applies by virtue of paragraph 4 of schedule 18 to the Finance (No. 2) Act 2023.

HMRC may be notified by the filing member using either:

• compatible software
• the Pillar 2 online dashboard available from the Business Tax Account

For the software to be compatible software it must be capable of providing all of the information and in the format as is required at Submit Below-Threshold Notification: Pillar 2.

2.3 Overseas return notification

2.3.1 Content of submission

This section has force of law for Multinational Top-up Tax purposes under paragraph 10(8) of schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 10 of schedule 14 applies by virtue of paragraph 4 of schedule 18 to the Finance (No. 2) Act 2023.

The ORN must contain:

• the start and end dates of the accounting period the ORN relates to
• the date the GIR was filed with the other authority
• the two-letter country code of the authority that has received the GIR as identified by the International Organization for Standardization’s ISO 3166 standard
• the name of the entity that submitted the GIR to that other authority
• the Tax Identification Number (TIN) of that entity, and the ISO 3166 two-letter country code of the authority that issued the TIN
• such other metadata as is required to successfully submit the ORN to HMRC’s systems

2.3.2 Method of submission

This section has force of law for Multinational Top-up Tax under Paragraph 10(7) of Schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 10 of Schedule 14 applies by virtue of paragraph 4 of Schedule 18 to the Finance (No. 2) Act 2023.

The ORN must be provided using software that is capable of providing all of the information and in the format specified at Submit Overseas Return Notification: Pillar 2.

2.4 Information return

2.4.1 Content of submission

This section has force of law for Multinational Top-up Tax under Paragraph 10(3) of Schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 10 of Schedule 14 applies by virtue of paragraph 4 of Schedule 18 to the Finance (No. 2) Act 2023.

The information return submission must contain:

• the pillar 2 reference for the group
• the information required to meet the requirements of the GloBE Information Return published by the OECD at Tax Challenges Arising from the Digitalisation of the Economy — GloBE Information Return (January 2025) — OECD
• such further meta-data as specified in the submission format that is required to successfully submit the information return to HMRC’s systems

2.4.2 Method of submission

This section has force of law for Multinational Top-up Tax under Paragraph 10(7) of Schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 10 of Schedule 14 applies by virtue of paragraph 4 of Schedule 18 to the Finance (No. 2) Act 2023.

The filing member for the group is required to submit the information return using software that is capable of providing all of the information and in the format specified at Secure Data Exchange Service: Pillar 2.

The information return must be provided in an XML format that conforms with the GloBE Information Return XML Schema published by the OECD at GloBE Information Return (Pillar Two) XML Schema — OECD.

2.4.3 Amendments to the Information return

This section has force of law for Multinational Top-up Tax under Paragraph 11(4) of Schedule 14 to the Finance (No. 2) Act 2023. For Domestic Top-up Tax, paragraph 11 of Schedule 14 applies by virtue of paragraph 4 of Schedule 18 to the Finance (No. 2) Act 2023.

An amendment to an information return must be submitted using software that is capable of providing all of the information and in the format specified at Secure Data Exchange Service: Pillar 2.

The amended information return must be provided in an XML format that conforms with the GloBE Information Return XML Schema published by the OECD at GloBE Information Return (Pillar Two) XML Schema — OECD.

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