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Pillar two in the UK: start date deferred

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HM Treasury has confirmed that the implementation of the OECD Inclusive Framework’s global minimum tax (pillar two) rules in the UK will take effect for accounting periods beginning on or after 31 December 2023 – and not April 2023 as originally proposed. 

In a letter to respondents to the UK’s pillar two consultation, the Financial Secretary to the Treasury, Lucy Frazer MP, said: ‘This will give businesses an appropriate lead-in time before implementation and allow the policy to benefit from progress on the international process, while maintaining the UK as a leader in implementing these reforms. The government will continue to work with the international community and monitor wider progress on implementing these reforms.’

The revised start date brings the UK into line with the likely implementation date in other countries, particularly in the European Union.

The announcement makes no reference to the undertaxed payments (or profits) rule (UTPR) (which was due to take effect from 1 April 2024), so it remains to be seen whether that will be deferred.  
Draft legislation will be published, as originally expected, in summer 2022.

Issue: 1579
Categories: News
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