Guernsey Issues Guidance on Pillar 2 Registration

In October 2025, Guernsey issued the Guernsey Pillar 2 Brief: Issue 1 which includes further detail on the registration process.

Section 20 of the Guernsey Pillar 2 Regulations requires every Domestic Constituent Entity of a Qualifying MNE Group (or a Domestic Joint Venture and Domestic Joint Venture Subsidiary) to register with the Tax Authority.

A Qualifying MNE Group is required to ensure that one Domestic Constituent Entity is appointed as the Domestic Filing Entity (which must be notified to the Tax Authority). The Domestic Filing Entity is responsible for registering all other Domestic Constituent Entities, Domestic Joint Ventures and Domestic Joint Venture Subsidiaries of the Group.

Registration is due the later of 12 months from the start of the first Fiscal Year commencing on or after 1 January 2025 or 6 months from the date that the Entity becomes a member of the MNE group.

The October Pillar 2 Brief confirms that the process of appointing the Domestic Filing Entity and the registration of Domestic Constituent Entities is combined into one step and that there will be only one registration for both DTT and MTT purposes.

An online registration form will be launched as a stand-alone page during the fourth quarter of 2025 and will be included on Pillar Two – States of Guernsey.

The online system for the submission of the DTT and MTT returns (and related notifications) is being developed and it is anticipated to be available in 2026.

DTT Cessations

Note that an earlier notification may be required in the case of a cessation. 

Under Section 35 of the Regulations, before an Entity:

-enters liquidation, dissolution, any other form of winding up or administration, or

-ceases to be located in Guernsey,

the Domestic Filing Entity of the Group must notify the Director of the estimated DTT liabilities for all relevant periods that will be allocated to the Entity in the relevant DTT returns and the Entity must make payment on account of the estimated amounts.

The “relevant periods” are

-all Fiscal Years for which a DTT return has not yet been submitted by the Domestic Filing Entity, and

-the period commencing on the day immediately following the end of the most recent completed Fiscal Year and ceasing with the date the entity entered into liquidation or ceased to be located in Guernsey.

Payment is due no later than the earlier of

– 30 days immediately following the notification to the Director or

– the date the entity entered into liquidation or ceased to be located in Guernsey.

A temporary DTT Cessation Form has been issued. The DTT Cessation Form must be submitted via post or email.