United Kingdom Tax Agency Issues Guidance on Transitional Approach to Global Information Return Filings, Exchanges

May 27, 2026, 5:00 AM UTC

The United Kingdom HM Revenue and Customs May 19 issued a guidance on the transitional approach to the central filing and exchange of Global Information Returns (GIRs) under Pillar Two, following OECD guidance. The guidance includes that: 1) the transitional approach applies where the GIR filing deadline is no later than Dec. 31; 2) the local filing of GIRs in the U.K. aren’t required if they are centrally filed, they are received within six months, and an overseas return notification (ORN) is submitted on time; 3) late filing penalties are reduced to nil if valid ORNs and GIRs are filed ...

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