Finance (No. 2) Act 2023 has now implemented the income inclusion rule aspects of the OECD’s Pillar Two model rules into UK tax law with effect for accounting periods beginning on or after 31 December 2023. Draft legislation for the UK’s implementation of the undertaxed profits rule aspects of those template rules has also recently been published. The UK’s resultant multinational top-up tax (MTT) regime will be endlessly complex. It should, however, be possible to summarise the essence of MTT relatively succinctly and then use that summary to highlight essential statutory provisions within it.
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Finance (No. 2) Act 2023 has now implemented the income inclusion rule aspects of the OECD’s Pillar Two model rules into UK tax law with effect for accounting periods beginning on or after 31 December 2023. Draft legislation for the UK’s implementation of the undertaxed profits rule aspects of those template rules has also recently been published. The UK’s resultant multinational top-up tax (MTT) regime will be endlessly complex. It should, however, be possible to summarise the essence of MTT relatively succinctly and then use that summary to highlight essential statutory provisions within it.
If you are not a subscriber, subscribe now to read this content.
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