Pillar Two: Domestic Registration Requirements

The Model GloBE Rules and the EU Minimum Tax Directive do not provide any requirement for taxpayers to register as being in scope of the GloBE Rules or to de-register when they fall out of scope.

However, many jurisdictions will require GloBE registration for administrative purposes.

The approach from the legislation issued to date has been inconsistent, with some including relatively detailed registration provisions and others being silent on the issue.

The table below outlines the GloBE registration obligations from the legislation (enacted and draft) issued to date (where a registration obligation has been specifically stated), including citations.

Country Registration Provision
AustriaArticle 76 of the Law provides that the UPE can elect an entity in Austria to file and pay on behalf of the minimum tax group members. If no election is made, the responsibility falls to (1) the highest group entity located in Austria or (2) the most economically significant business unit located in Austria. If the UPE makes an election for a different entity, this must be notified to the tax office before the end of calendar year in which the financial year ends. eg for 2024 fiscal years that coincide with the 2024 calendar year, this must be provided by December 31, 2024. The notification is provided on the FinanzOnline website.
BahrainArticle 17 of the Law provides that the Filing Constituent Entity shall register with the Tax Authority in accordance with the rules prescribed by the Regulations.
Article 62A of the Regulations requires registration no later than 120 days from the first day of the Transition Year. This is defined as the first fiscal year for which a Multinational Enterprise Group comes within the scope the DMTT, irrespective of whether it had been within scope in any fiscal year other than the immediately preceding fiscal year.

However, Article 62B of the Regulations provide that where the 750 Million Euro threshold is met for at least two of the four fiscal years immediately preceding January 1, 2025, a Filing Constituent Entity must register no later than 30 days from January 1, 2025.

The Tax Authority may also require any Excluded Entity to register for QDMTT purposes.

Article 18 of the law provides that the following Entities shall appoint one among them as the Filing Constituent Entity, which shall be responsible for paying the Tax and handling all tax administration matters, including registration, filing of returns, making elections, and submitting notifications:

-The Constituent Entities of a Multinational Enterprise Group that are located in Bahrain and who meet the 750 million euro revenue threshold
-A Joint Venture and its Joint Venture subsidiaries.

The Tax Authority may also require any Excluded Entity to register for QDMTT purposes.

Article 18 of the law provides that the following Entities must appoint one among them as the Filing Constituent Entity, which shall be responsible for paying the Tax and handling all tax administration matters, including registration, filing of returns, making elections, and submitting notifications:

-The Constituent Entities of a Multinational Enterprise Group that are located in Bahrain and who meet the 750 million euro revenue threshold

-A Joint Venture and its Joint Venture subsidiaries.
BarbadosSection 45(1) of the Law provides that an in-scope entity is required to register with the tax authority within 12 months after the last day of the first fiscal year that it is a qualifying entity.
BelgiumThe May 2024 Royal Decree includes a requirement for entities subject to the Belgian IIR, UTPR or QDMTT to obtain a government issue KBO number.

The notification of a group of MNEs or a large national group must be made no later than 30 days after the beginning of the tax year for which the group of MNEs or the large national group falls within the scope of the Belgian GloBE rules.

However, in order to give those who have already started or will soon start their first tax year sufficient time to collect the requested information, the notification period will in any case be granted until 45 days after the publication in the Belgian Official Gazette of a Royal Decree of 15 May 2024. The Royal Decree was published on May 29, 2024, which means that the notification deadline for existing notifications was July 13, 2024. On June 21, 2024, the Belgian Tax Authorities published a FAQ which clarifies that as this falls on a Saturday, the registration deadline is extended to the next working day (ie July 15, 2024).

On July 2, 2024, the Belgian Tax Authority extended the notification deadline to September 16, 2024 for groups that are not making advance payments in 2024 for the QDMTT or the IIR.

The notification form includes a significant amount of information for registration.
BrazilArticle 2(8) of the Normative Instruction provides that entities located in Brazil are required to verify whether they are part of a Multinational Group of Companies and whether they are subject to the QDMTT rules.
CyprusSection 47(1) of the Law requires each constituent entity in Cyprus to notify the Taxation Department by the GloBE Information Return (GIR) filing deadline. The notification is made once and is valid for each financial year following the first financial year for which the notification was made.
Czech RepublicNo. The original Draft Law required an MNE group to submit an application for registration for top-up tax no later than 15 days from the date on which they were liable. However, this was not included in the final enacted law.
DenmarkSection 55 of the Law provides that a MNE group within the scope of Pillar Two in Denmark is required to notify the Customs and Tax Administration within 6 months after the end of the fiscal year.

Section 2 of the draft Executive Order of December 18, 2024 states that the information to be provided will be:

1) Name and address.
2)CVR number. If the group entity does not have a CVR number, the SE number must be provided
3) From which date the group entity is covered by the Minimum Taxation Act.

Note that all Danish companies, irrespective of whether they are covered by the Minimum Taxation Act, need to declare their Pillar 2 status in the 2024 tax return. Field 540 asks if the company is part of a group that has had a turnover of more than EUR 750 million annually in the last four years and Field no. 540a asks if the company is a group entity subject to tax under the Minimum Taxation Act.
EstoniaArticle 54-11(10) of the Law provides that the UPE located in Estonia shall designate the entity filing the minimum tax return in another Member State or, if the group does not have an entity in another Member State, in a third country that has an eligible competent authority agreement for the reporting financial year with the minimum-tax jurisdictions in which other group entities are located.
FranceArticle 223 WW(1) of the 2024 Finance Act provides that a constituent entity located in France that is a member of an in-scope MNE or domestic group is required to confirm to the tax administration in its income statement its membership in the group. It must also indicate the identity of the ultimate parent entity of the group and, where applicable, the entity filing the GIR as well as the jurisdiction in which they are located.

Article 1679 deci provides that constituent entities subject to the QDMTT or UTPR are permitted to designate a single entity from among the constituent entities liable to pay the tax and file the GloBE tax return/statement of settlement on their behalf. Decree No. 2024-1126 of December 4, 2024 inserts a new Article 46c-0 ZZB into the General Tax Code to provide that if a designated filing entity is used for QDMTT/UTPR purposes, that in addition to the above information in Article 223 WW, the filing constituent entity is also required to provide the identity of the QDMTT/UTPR filing constituent entity.

The Pillar 2 Notification Form (N° 2065-INT-SD 2025) was subsequently issued.
GermanySection 3(1) of the German GMT Law provides that German resident constituent entities of corporate groups form a Minimum Tax Group. The Group Parent is liable to file and account for top-up tax under the IIR, UTPR and DMTT on behalf of the Minimum Tax Group.

Section 3(3) of the GMT Law provides that the UPE is the Group Parent if it is located in Germany. If this does not apply the German parent entity of the German resident constituent entities is the Group Parent. In all other cases, a designated German Constituent Entity is treated as the Group Parent. If not, the economically most relevant German resident constituent entity is deemed to be the Group Parent.

These tests apply based on the circumstances at the end of the tax period.

Section 3(4) stated that the Group Parent is required to electronically notify the Federal Central Tax Office of its status as a Group Parent within two months after the end of the tax period (ie February 28, 2025 for the 2024 fiscal year).

Changes to the status of the Group Parent, must be notified immediately by the previous Group Parent.

As the Group Parent pays top-up tax on behalf of the minimum tax group, members of the members of the minimum tax group whose top-up tax is attributed to the Group Parent obliged to compensate the Group Parent for their share of the top-up tax.

On October 17, 2024, Germany released the template for its Group Parent Notification Form (see below).

The 2024 Annual Tax Act (passed by the Upper House of Parliament on November 22, 2024) provides that a single constituent entity in Germany will be classed as group parent for the purposes of the German minimum tax group provisions. 
GuernseySection 20 of the Regulations requires every Domestic Constituent Entity of a Qualifying MNE Group, 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.

If an MNE Group expects no longer to have any Domestic Entities, the Domestic Filing Entity for the Group may, with the consent of another Entity of the Group located outside Guernsey, appoint that other Entity to replace it as Domestic Filing Entity. Where an MNE Group ceases to have any Domestic Entities and an Entity of the Group located outside Guernsey has not been appointed as Domestic Filing Entity, the Ultimate Parent Entity of the Group is deemed to be immediately appointed by the Group as Domestic Filing Entity.

The deadline for registration is the later of:

• 12 months from the start of the first Fiscal Year commencing on or after 1 January 2025 of the MNE Group of which any of the following is a member:
(i) a Domestic Constituent Entity;
(ii) a Domestic Joint Venture;
(iii) a Domestic Joint Venture Subsidiary;

• 6 months from the date that such an Entity becomes a member of the MNE Group.
Hong KongSchedule 62(5) of the draft law provides that each Hong Kong constituent entity of an in-scope MNE group will be required to file an annual notification (“top-up tax notification”).

The top-up tax notification is required for notifying the Tax authority that an MNE group has come within the scope of the global minimum tax and HKMTT, as well as identifying the entity and jurisdiction from which Hong Kong will receive the GIR and the local entities for which the obligation to file the top-up tax return will be lifted when certain conditions are met.

The top-up tax notification is to be filed within 6 months after the last day of the reporting fiscal year.
An in-scope MNE group can appoint one designated local entity to file a top-up tax notification so as to relieve other Hong Kong constituent entities from the filing obligation.
HungarySection 44(1) of the Law provides that a Hungarian entity within the scope of the GloBE rules (or a designated domestic entity acting on its behalf)  is required to notify the tax authority within 12 months from the beginning of the tax year concerned (ie December 31, 2024 for the 2024 tax year).

The Autumn Tax Package as published in the Official Gazette on November 27, 2024 provides that the information to be provided will be:

– the identification information of the group members, including their value added tax number, intra-community VAT number (if any), the State in which they are resident and their classification under the GMT law

– information on the overall corporate structure of the multinational group or large domestic group, including the controlling stakes held by each group member in other group members.

On November 15, 2024, the Hungarian Tax Authority issued draft forms for the registration notification under Article 44(1) of the Minimum Tax Act, and the appointment of a domestic filing entity under Article 3(47).In December 2024, the Hungarian Tax Authority issued Updated Instructions for the submission of the registration forms. They can now be submitted via the ONYA (Online Nyomtatványkitöltő Alkalmazás) web portal on the e-services portal of the Hungarian Tax Authority Website.
IndonesiaSection 65(5) of the Regulation provides that each Constituent Entity of the MNE Group within the scope of the GloBE rules in Indonesia must submit a GloBE Notification to the Director General of Taxes within 15 months after the end of the Tax Year. This must be submitted as an attachment to the Annual Income Tax Return. The notification is not required if a GloBE Information Return has been submitted.
IrelandSection 111AAH of the Law provides that an Irish entity subject to top-up tax (either under the IIR, UTPR or DMT) is required to notify the tax authority within 12 months from the last day of the first fiscal year during which it is a relevant parent entity, immediately following a fiscal year for which it was not a relevant parent entity. Amended Section 111AAH of the Finance Act 2024 provides that the registration date is December 31, 2025, where the registration date is earlier than 31 December 2025.
Isle of ManSection 28 of the Law requires every Domestic Constituent Entity of a Qualifying MNE Group, 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.

The deadline for registration is the later of:

• 12 months from the start of the first Fiscal Year commencing on or after 1 January 2025 of the MNE Group of which any of the following is a member:
(i) a Domestic Constituent Entity;
(ii) a Domestic Joint Venture;
(iii) a Domestic Joint Venture Subsidiary;

• 6 months from the date that such an Entity becomes a member of the MNE Group.

JerseyUnder Article 21 of the MCIT Law, an MCIT reporting entity in relation to an in-scope MNE group must register each Jersey constituent entity with the Comptroller:

– before the end of the first fiscal year for which the MCIT applies to the in-scope MNE group; or

-if an entity subsequently becomes a Jersey constituent entity in relation to the in-scope MNE group (and, accordingly, liable to be registered), before the end of the period of 6 months beginning with the day on which the entity becomes a Jersey constituent entity.

Under Articles 15/16 of the IIR Law, an MCIT reporting entity in relation to an in-scope MNE group must given written notice to the Comptroller stating whether the reporting entity is the qualifying entity in relation to the MNE group (and is accordingly required to file the GloBE information return). The notification must be filed no later than 15 months after the end of the fiscal year (with an 18-month deadline for the Transition Year).

Note that the MCIT is not a QDMTT under the OECD GloBE rules.
KuwaitArticle 3 of the introductory provisions to the Law provides that MNE groups must register for DMTT purposes within 6 months from the date of entry into force of the provisions of the draft law to avoid an administrative fine.
LatviaArticle 4(1) of the Law provides that a UPE of an MNE group located in Latvia must nominate a designated filing entity in any other Member State other than Latvia for the preparation of the GIR or, if the group has no constituent entity in another Member State, in a third-country jurisdiction that has, for the reporting fiscal year, a qualifying competent authority agreement in effect with Latvia.
LiechtensteinArticle 5(3) of the GloBE Regulation (as inserted by the December 2024 amended GloBE Regulation) provides that domestic constituent entities of an in-scope MNE or domestic group (including excluded entities) must submit a registration notification to the tax administration within 6 months after the end of the financial year after the group has entered the scope of the GloBE rules in Liechtenstein.
LithuaniaUnder Article 8(2) of the Law the main parent entity whose location is in Lithuania must appoint a designated data reporting entity whose location is in another European Union member state that applies the provision of the minimum effective level of taxation.

Under Article 8(3) of the GMT law, if the MNE group does not have taxable entities located in other European Union member states, the main parent entity must appoint a designated data reporting entity located in the jurisdiction of a third country, with which Lithuania applies a relevant competent authority agreement in of the financial year for which the supplementary tax information declaration is submitted.

Article 8(6) of the GMT law provides that the main parent entity, whose location is in Lithuania, must submit a notification to the State Tax Inspectorate (‘STI’) about the designated data-providing entity.

Section 18 of the Order on Information Notices (the ‘Order’) states that the report on the designated entity is completed and submitted to the STI no later than within 12 calendar months from the last day of the reporting financial year.

Notification of the designated entity is provided by MNEs main parent entity, whose location is in Lithuania.

Section 20 of the Order provides that other taxable entities belonging to the same MNE group located in Lithuania do not have an obligation to submit a Notice of Designated Entity, if it was performed by the main parent entity of the MNE group, whose location is in Lithuania.
LuxembourgSection 49 of the Law requires any constituent entity located in Luxembourg to register with the Tax Authority within 15 months of the end of the relevant fiscal year (18 months for the transition year), when it is within the scope of the Pillar Two GloBE Rules.
MaltaThe relevant aspects of the submission of a GloBE Information Return (GIR) are included in Regulation 5, as provided in the EU Directive. However, as Malta is opting for the Article 50 postponement, the standard filing obligations are amended in Regulation 11.

Regulation 11 provides that a UPE of an MNE group located in Malta must nominate a designated filing entity in any other Member State other than Malta (and which Member State has not elected for a delayed application of the IIR and UTPR under Article 50(1) of the European Union Global Minimum Tax Directive) or, if the group has no constituent entity in another Member State, in a third-country jurisdiction that has, for the reporting fiscal year, a qualifying competent authority agreement in effect with Malta.
New ZealandA new Section 78H in the Tax Administration Act 1994 provides that a constituent entity of an MNE group must apply to the Commissioner for registration of the MNE group within 6 months after the end of any fiscal year ending on or after 1 January 2025 when it is subject to the GloBE rules.
PortugalArticle 46 of the Law requires an in-scope group to register with the Portuguese Tax Authority within 9 months after the end of the financial year tax (regardless of whether this period ends on a business day or not), in which:

• The group of which the constituent entity is a member becomes covered by the Portuguese GloBE rules; or,

• There are changes to any of the information in the registration declaration.

In the transition year, the registration deadline is extended to 12 months after the end of the relevant financial year.
SingaporeSection 31 of the Law provides that an MNE group subject to the GloBE rules in Singapore is required to register with the Singaporean tax authority. The ultimate parent entity of the MNE group must, within 6 months after the end of the financial year.
SpainArticle 18(1) of the draft regulations provide that any constituent entity located in Spain that forms part of a large multinational or domestic group is required to file an information return withthe tax authority and must notify the Tax Authority of the identification, the start and end date of the tax period and the country or territory in which the ultimate parent entity is located, when the latter is required to file the return or, if it is not required to file the return, it must notify the Tax Authority of the identification and the country or territory in which the entity designated to file the return is located. This must be filed at least 3 months before the GIR filing deadline.
SwedenChapter 7 of the amended Tax Procedures Act requires all Swedish group entities that are part of a group falling within the scope of the GloBE rules in Sweden to register with the Swedish Tax Agency. The deadline for registration is 15 months from the tax year end in which the registration obligation arose.
SwitzerlandArticle 19 of the Pillar Two Ordinance states that entities subject to the IIR/QDMTT are required to register by the filing deadline for the GloBE Information Return
ThailandSection 54 of the Decree requires an in-scope MNE to submit a notification within 15 months of the end of the reporting period (18 months in the transitional year). This will include information on the UPE, including the country where it is located and the designated CE responsible for filing the GloBE Information Return.

An exemption applies if the CEs appoint a designated filing entity to file the notification on their behalf.
UAEArticle 13 of the Cabinet Decision requires any Entity that is subject to the DMTT and a Domestic Designated Filing to register with the Federal Tax Authority (in the form and manner and within the timeline prescribed by it).
UKSchedule 14(6) of the Finance Act requires that when an MNE group becomes a qualifying multinational group it is required to register with the UK tax authority. This applies even if no top-up tax is due.

Groups must register with HMRC within 6 months of the end of the first accounting period that started on or after 31 December 2023 which makes them subject to the Pillar Two rules.

The Pillar 2 Top-up Taxes Registration Notice provides that a group or single entity who:

-has at least 1 entity located in the UK

-has made consolidated group annual revenues of €750 million or more within 2 of the last 4 accounting periods

is required to use the online service to register and report for Pillar 2 top-up taxes in the UK.

Only the filing member for the group can use the online service. This will be the ultimate parent entity (UPE) by default, but the UPE can nominate another group entity as the filing member when it registers for Pillar 2 purposes. On November 20, 2024, the UK issued guidance on how to replace a filing member for Pillar 2 purposes (https://www.gov.uk/guidance/replace-the-filing-member-for-a-pillar-2-top-up-taxes-account). This is submitted via an online service and the new filing member will need to provide the group’s Pillar Two top-up taxes ID, the date the group first registered to report Pillar Two top up taxes in the UK, contact details and preferences, for one or two individuals or teams in the group and a contact postal address for the group.
VietnamArticle 14(6) of the Draft Decree provides that MNE groups with Constituent Entities in Vietnam are required to register within 90 days from the end of the reporting fiscal year using form No. 01-DKTD-DVHT.

Article 6(3) of the Resolution (Article 14(4) of the Draft Decree) provides that if an MNE group has more than one constituent entity in Vietnam, the UPE or a constituent entity in Vietnam is required to submit a notification to designate the filing constituent entity within 30 days from the end of the reporting fiscal year using Form No. 01/TB-ĐVHT.