A key aspect of preparing for P2 is meeting compliance obligations. While P2 is a global project, many compliance requirements are introduced locally. MNEs should track four main obligations:

  • GloBE Information Return (GIR);
  • GIR notifications;
  • Top-up Tax Return (TTR); and
  • P2 registrations.
GIR

The GIR is a standardised return covering all P2 information, including group structure and jurisdictional ETR calculations. It is due 15 months after year-end (18 months for 2024; first deadline June 30, 2026).

P2 allows filing the GIR in one P2 jurisdiction with an automatic exchange with others. Two mechanisms have currently been developed to facilitate such an exchange – DAC9 and the Multilateral Competent Authority Agreement (MCAA). DAC9 applies within the EU and the MCAA is open for signature by all jurisdictions. Not all P2 jurisdictions have signed the MCAA yet, but this is expected before the first deadline.

As the U.S. did not implement P2, U.S. MNEs cannot file in the jurisdiction where they are headquartered. For U.S. MNEs, choosing where to file is therefore a key decision, assuming they have to keep filing the GIR after implementation of the G7 agreement (see our previous Snippet). It makes sense to pick a jurisdiction that exchanges with the most other jurisdictions to reduce filing obligations.

GIR notification

If the GIR has been filed in one jurisdiction and is exchanged, most P2 jurisdictions require a notification to inform them where the GIR has been filed. Deadlines and formats differ by jurisdiction, so it is key to keep tracking these.

TTR

The GIR is an information return only. Most P2 jurisdictions therefore require an MNE to file one or more TTRs to collect the tax due under P2. These TTRs are local obligations, with varying deadlines, some even earlier than the GIR (e.g., Hungary requires MNEs to file a return and pay Top-up Tax in November 2025 already). 

P2 registration

Certain P2 jurisdictions also require MNEs to register as in-scope P2 group, or to register an entity as taxpayer for P2 purposes. These obligations are local and not part of OECD rules, so monitoring local requirements is essential – e.g., Belgium required a registration in the middle of 2024.

Takeaway

P2 compliance is not just about the GIR – it is key to monitor all notifications, TTRs, and local registrations with varying deadlines and requirements to ensure US MNEs are compliant.

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