Pillar 2: Mandatory registration in the UK and discussions in the EU Parliament

The United Kingdom, one of the most important economic nations in Europe, has specified the implementation of Pillar 2. Specific registration requirements for multinational enterprise groups will apply there as of June 30, 2025. Failure to comply with these requirements in due time entails the risk of sanctions.

These companies are affected

A group of companies is required to register if it has at least one taxable entity in the UK – this can be a company, permanent establishment or other local branch – and the consolidated group turnover has exceeded EUR 750 million in at least two of the last four financial years. If both conditions are met, an entity within the group must be registered with HMRC.

Registration must take place no later than six months after the end of the first financial year beginning on or after December 31, 2023. For many companies whose financial year corresponds to the calendar year, June 30, 2025 is therefore the relevant deadline. Click here to get to the registration page.

Registration via Government Gateway account

Registration is made digitally via the HMRC portal and requires a valid Government Gateway account. In addition, companies will in future need their own Pillar 2 tax identification number, which will only be issued as part of the registration process. In practice, the Ultimate Parent Entity (UPE) is often responsible for registration unless another entity is designated for this purpose.

We have compiled the most important details about Pillar 2 for you here.

What else is new with Pillar 2?

The geopolitical and economic impact of minimum taxation is currently the subject of intense debate at EU level. This has intensified following the USA’s announcement that it will not ratify Pillar 2. EU Tax Commissioner Wopke Hoekstra made it clear in mid-May that the Commission was determined not to allow any “bureaucratic nightmares” caused by uncoordinated national solo efforts.

Central guidelines for the EU in the debates: Fairness and competitiveness. Although a certain flexibility in the technical implementation is signaled, a step backwards in the implementation for European companies is (currently) ruled out. At the same time, the Commission emphasizes that Pillar 2 should not be seen as a response to the US approach, but as an instrument of international tax justice.

Conclusion

Companies should keep an eye on the registration obligations in the United Kingdom as of June 30, 2025 and take preparatory measures now, as the notifications can only be made by the companies themselves.

At the same time, Pillar 2 remains on the move – also at EU level. We will keep you up to date with the latest news on this matter.