Overview past and upcoming Pillar 2 notification deadlines
Dear reader,
We would like to take the opportunity to provide you with an overview of the past and upcoming Pillar 2 notification deadlines.
Content
1. Kuwait: 30 September 2025
2. Romania: updated deadline to 31 December 2025
3. Liechtenstein – 31 December 2025
4. Past deadlines in 2024 and 2025
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1. Kuwait: 30 September 2025
Kuwait has introduced a Domestic Minimum Top-up Tax (DMTT) and the Executive Bylaws provide the details of the registration requirements. A Kuwait Constituent Entity (CE) must be designated to represent the MNE Group. If the Ultimate Parent Entity (UPE) of the MNE Group is located in Kuwait, then the UPE must be the designated CE.
Which entities are required to file?
The Kuwait DMTT is effective from 1 January 2025. Under the general rule, all in-scope entities (including CEs and PEs of Pillar 2 groups) must register with the Kuwait Tax Authority (KTA) within 120 days of becoming subject to the DMTT.
For tax periods commencing between 1 January 2025 and 1 June 2025, the registration deadline is 30 September 2025. For tax periods commencing on or after 2 June 2025, the registration deadline is 120 days from the commencement of tax period or from being considered in-scope and subject to DMTT.
Process for filing
Registration is through an electronic portal managed by the Kuwait Ministry of Finance / KTA. The Executive Bylaws states that all CEs, PEs, and JVs of an MNE Group must register, and one entity must be designated to represent the group.
The following details will be required for registration:
- Full legal name of the UPE.
- Full legal name of the CEs in Kuwait. This includes subsidiaries, minority-owned subgroups, joint ventures, and permanent establishments, as defined under DMTT.
- The MNE group's ownership structure, which must be stamped and signed by an official from the company.
- Proof of affiliation for the CEs in Kuwait, such as articles of association or other legal documents.
- The MNE group's consolidated financial statements for the last four fiscal years.
- Authorization letters pertaining to DMTT registration for the following:
- The UPE approving the Kuwait CE to be the lead registered and main filing entity.
- The Kuwait designated CE authorizing a local tax advisor.
- A letter to be issued by UPE authorizing its employee / officer (in the Group) for dealing with all tax matters in Kuwait.
Note: The acceptable file format is PDF not exceeding 20 MB. In addition, please note that a local Kuwait mobile number is required for the registration purposes, while doing a sign up for the first time on the MOF portal.
Registration is expected to be done entirely through the online portal, so there is no downloadable PDF/Word form. KPMG in Kuwait can assist with the registration requirements and has developed an Excel template with all the required information.
Practical considerations
- What are the penalties for late filing?
- Is there anything else that a client should know about the process of registering for the DMTT in Kuwait?
KTA will impose penalties if entities fail to register by the registration deadline. Please note that where there is a delay in registration, under the DMTT law, the delay penalty for late registration is KD 3,000 per entity. Additionally, under Article 76 of the Executive Bylaws, based on the data available with the KTA, the KTA can register a taxpayer if they fail to comply with the DMTT registration deadline and notify them within 30 days from the date of registration. This is done without prejudice to any applicable penalties or consequences.
- Safe Harbours: Even if no DMTT is payable (i.e., due to De Minimis, ETR, or Routine Profits tests), registration and filing of DMTT return is still mandatory.
- MOF oversight: The MOF has discretion to mandatorily register entities that fail to do so on time and apply applicable penalties.
2. Romania: updated deadline to 31 December 2025
A Designated Filing Entity (“DFE”) in Romania was initially required to submit a notification form to the Romanian tax authorities within six months after the end of the fiscal year during which the group falls within the scope of the GloBE rules. For calendar year taxpayers, the deadline for the DFE to notify the Romanian tax authority was initially 30 June 2025. However, the deadline for submitting a notification form to the Romanian tax authorities is officially postponed to 12 months following the end of the financial year for the first year of application of the Pillar Two rules, i.e., 31 December 2025 for calendar year taxpayers.
For the upcoming years, the deadline will remain 6 months following the end of the financial year.
Which entities are required to file?
The only entity required to make this filing is the Romanian DFE and MNE Groups have discretion as to which Romanian entity to nominate.
If an MNE Group only has one Romanian Constituent Entity, this entity would automatically become the Romanian DFE, and no notification would be required.
What information needs to be reported?
The draft Order currently states that the following information must be included in the notification:
- Information about the taxpayer which is submitting the notification (name, tax ID number, address, type of entity for Pillar Two purposes – i.e. ultimate parent entity, constituent entity, locally designated entity).
- Information about the group of companies the taxpayer is a member of (name of the MNE group / large-scale domestic group that is usually used in preparing consolidated financial statements).
- Information about all the Romanian constituent entities (name, address, tax ID number, whether the entity is a designated entity or not).
- Information about any designated entity which will declare and pay the jurisdictional top-up tax.
- Information about the fiscal year applicable for Pillar Two purposes.
Process for filing
The notification must be submitted electronically to the Romanian tax authorities, using a qualified electronic signature.
Currently, it appears the constituent entity which submits the Notification can be different from the local designated constituent entity which declares and pays the jurisdictional top-up tax. It remains to be seen what the final version of the form will look like once all the administrative approvals have been finalized.
3. Liechtenstein – 31 December 2025
Which entities are required to file?
Local constituent entities and local excluded entities are required to register within six months after the end of the fiscal year during which the group falls within the scope of the GloBE rules. For calendar year taxpayers, the deadline was initially 30 June 2025. However, Liechtenstein has amended their registration deadline from 6 months to 12 months. This means that for calendar year taxpayers, the new deadline is now 31 December 2025 (instead of 30 June 2025).
What information needs to be reported for the initial notification?
Impacted entities will need to collect the following information:
- Name, PEID (i.e., Tax ID) and characteristic (e.g., CE, UPE, MOPE, etc.) of Lichtenstein entity
- Name and address of UPE
- Name and address of CE who will submit Lichtenstein top-up tax return
- Name and address of CE who will pay the Lichtenstein top-up tax
- Name and address of CE who will submit the IIR tax return
- Name and address of CE who will submit the GloBE Information Return
- Name and email address for queries on the registration form
Process for filing
Each impacted Liechtenstein entity needs to email a copy of the registration form to the Liechtenstein tax administration (globe@llv.li). This registration form can be found here.
Please note that the form only covers one Liechtenstein entity so if an MNE Group has more than one Lichtenstein entity, they will need to submit multiple copies of this form.
Practical considerations
Penalties are possible under the law and are listed below:
- Transgression punishable by a fine of up to CHF 1,000 in serious cases or in the event of a repeat offense, up to CHF 10,000
- Any person who, either intentionally or negligently, fails to comply with the obligation to submit the GloBE tax return is liable to a fine not exceeding CHF 250,000.
However, no fines will be imposed for violations or breach of procedural obligations committed within three years of the entry into force of the Pillar Two rules provided that appropriate measures have been taken to properly implement the provisions.
In addition to the above deadline, the Liechtenstein government has issued a public consultation document which outlines a further registration deadline of 15 months after the end of the fiscal year for local constituent entities that submit a GloBE Information Return. This is in addition to the above six-month deadline following the end of the fiscal year requiring local constituent entities and local excluded entities to register. Consultation is open until 2 May 2025 and adoption of this rule would not be before 1 January 2026.
4. Past deadlines in 2024 and 2025
Please find below the past deadlines in 2024 and 2025 for taxpayers that have a financial year that is equal to the calendar year. In case you need more details in relation to these obligations, please contact us.
In case your financial year deviates from the calendar year, the below deadlines might deviate, and the registrations might be due in the coming weeks / months.
- Bahrain; 30 January 2025.
- Belgium: either July 15, 2024, or September 16, 2024.
- Austria: December 31, 2024.
- Hungary: either December 31, 2024, or the last day of the second month following the last day of the tax year.
- Germany: February 28, 2025.
- Vietnam: March 31, 2025.
- France: May 19, 2025.
- Denmark: June 30, 2025.
- UK: June 30, 2025.
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