HMRC have made further changes to their Pillar Two guidance, with new sections on common reporting obligation misconceptions and the transitional safe harbour rules. ‘How to prepare for MTT and DTT’ has been updated to include the following:
details of HMRC webinars in autumn 2024 covering the scope of the UK Pillar Two legislation, including reporting obligations and transitional safe harbour rules - dates for the sessions will be announced ‘nearer the time’;
online registration for MTT and DTT is now available and the guidance sets out the various information required - the online service is expected to be extended later in 2024 to allow businesses to make payments on account and authorise agents, with third-party software options for Pillar Two returns also planned;
HMRC intend to publish further draft guidance ‘in the coming months’ on determining top-up tax amounts (covering F(No. 2)A 2023 Part 3 Chapters 6–8), and particular types of entities and structures;
new links have been added to OECD guidance documents, including the Administrative Guidance from June 2024, and Pillar Two illustrative examples;
a new ‘common misconceptions’ section notes that businesses can still have reporting obligations even where there is no tax liability; and
a new section has been added on transitional safe harbours.
The guidance also says that HMRC will continue to update the principal MTT and DTT legislation in F(No. 2)A 2023 for consistency with the UK’s international obligations, so further changes can be expected in forthcoming Finance Bills – including the safe harbour anti-arbitrage measure which has already been published in draft.
HMRC have made further changes to their Pillar Two guidance, with new sections on common reporting obligation misconceptions and the transitional safe harbour rules. ‘How to prepare for MTT and DTT’ has been updated to include the following:
details of HMRC webinars in autumn 2024 covering the scope of the UK Pillar Two legislation, including reporting obligations and transitional safe harbour rules - dates for the sessions will be announced ‘nearer the time’;
online registration for MTT and DTT is now available and the guidance sets out the various information required - the online service is expected to be extended later in 2024 to allow businesses to make payments on account and authorise agents, with third-party software options for Pillar Two returns also planned;
HMRC intend to publish further draft guidance ‘in the coming months’ on determining top-up tax amounts (covering F(No. 2)A 2023 Part 3 Chapters 6–8), and particular types of entities and structures;
new links have been added to OECD guidance documents, including the Administrative Guidance from June 2024, and Pillar Two illustrative examples;
a new ‘common misconceptions’ section notes that businesses can still have reporting obligations even where there is no tax liability; and
a new section has been added on transitional safe harbours.
The guidance also says that HMRC will continue to update the principal MTT and DTT legislation in F(No. 2)A 2023 for consistency with the UK’s international obligations, so further changes can be expected in forthcoming Finance Bills – including the safe harbour anti-arbitrage measure which has already been published in draft.
