What happened?
Countries worldwide have begun enacting procedures that require in-scope groups and entities to register before making Pillar Two payments. Before filing a GloBE Information Return (GIR) or, if applicable, a Qualified Domestic Minimum Top-up Tax (QDMTT) return, certain countries have requested advance registration and assigned taxpayer identification numbers.
Why is it relevant?
Generally, a GIR and QDMTT return must be filed within 15 months of the end of the GloBE reporting year (extended to 18 months in the first fiscal year that the multinational company and large domestic group is within scope). However, there are local country exceptions to this general timing. In anticipation of these filings, countries have begun to enact internal procedures.
Action to consider
Taxpayers should be keenly aware of the varying Pillar Two registration deadlines. For example, those taxpayers who already are subject to Pillar Two in Belgium must register within 45 days of the ‘15th May royal decree’ being published in the Belgian Official Gazette on 29 May 2024.