Taxpayer Identification Numbers (TINs) for Lloyd's Member Permanent Establishments (PEs) in CbCR & Pillar Two Reporting

This article sets out the approach agreed with HMRC regarding the completion of TIN fields for Lloyd's members in respect of Country by Country Reporting (CbCR) and GloBE Information Return reporting (GIR) under OECD Pillar Two. The following information is applicable for Lloyd's members with PEs in jurisdictions where Lloyd's file central aggregated market tax returns.

Background

In the United States, Canada and Singapore, Lloyd's operate central tax arrangements whereby income tax returns are filed on an aggregated market basis and in which a single market-level TIN applies to the filing.

Under these arrangements, members may not have a jurisdiction-specific TIN and this creates practical challenges for members who choose to report these jurisdictions as PEs given that the TIN field is mandatory.

Approach

Following discussion with HMRC, the below approach has been agreed for Lloyd's member TINs for CbCR and Pillar Two reporting:

For GIR purposes, the designated number must follow the format set out by the status message validation rules. Specifically, rule 70007 (see page 32 of the GloBE Information Return (Pillar Two) Status Message XML Schema) states the reference must be created in the format P2JJYYYYMMDDCCCXXX where:

• P2 is constant,
• JJ is the ISO Code of the jurisdiction of location of the Constituent Entity (SG - Singapore, CA - Canada),
• YYYYMMDD refers to the date of creation of the reference,
• CCC is a three letter reference to the company or group, and
• XXX is a unique number for the entity within the GIR e.g. 001, 002, 003 to differentiate between multiple entities with designated references in the same report.

Where a designated number is used in place of a TIN, the TypeofTIN field should be populated with code GIR3003.

Once assigned, this reference should be used on all future GIR and is superseded only in the case that a government or administration issues a tax reference or functional equivalent for the entity.