The designated New Zealand constituent entity will need to file the multinational top-up tax return.
The top-up tax return will be an online return, completed in myIR. This will be available from April 2027 ready for the Pillar 2 GloBE rules.
Return information required
All the details needed to calculate the top-up tax under the income inclusion rule (IIR) (including the domestic income inclusion rule (DIIR)) and the undertaxed payments rule (UTPR) will be in the GloBE information return (GIR).
The top-up tax return will require:
- the fiscal year end to which it relates
- the conversion rate used between the GIR and the top-up tax return
- the amount of top-up tax to pay, split between IIR, DIIR and UTPR.
All top-up tax amounts must be returned in New Zealand dollars.
Return timing
IIR and UTPR top-up taxes apply for fiscal years beginning on or after 1 January 2025.
DIIR top-up tax applies for fiscal years beginning on or after 1 January 2026.
For the 1st year that the rules apply to an MNE group, the top-up tax return will be due 20 months after the end of the fiscal year. For subsequent years, it will be due 16 months after the end of the fiscal year.
Remedial legislation
There is a proposed remedial law change that will impact the filing of the top-up tax return. This proposes:
- Filing a single top-up tax return under the designated constituent entity for all New Zealand constituent entities.
- Removing the need to file a top-up tax return when there is no top-up tax liability.
- Clarification of how time bar applies.
Contact us
You can email us with any questions.