The government has confirmed that the UK will apply new anti-avoidance rules in respect of the Pillar Two transitional country-by-country reporting (CbCR) safe harbour from 14 March 2024 with a view to legislate in a future Finance Bill to ensure they operate as envisaged without any unintended outcomes.
This follows the publication in December 2023 of the OECD’s third set of Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), which includes a technical reform to close off certain transaction-based tax avoidance mechanisms.
The government has confirmed that the UK will apply new anti-avoidance rules in respect of the Pillar Two transitional country-by-country reporting (CbCR) safe harbour from 14 March 2024 with a view to legislate in a future Finance Bill to ensure they operate as envisaged without any unintended outcomes.
This follows the publication in December 2023 of the OECD’s third set of Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), which includes a technical reform to close off certain transaction-based tax avoidance mechanisms.
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