Market leading insight for tax experts
View online issue

The saga continues: implementing Pillar Two in the UK

Speed read
The UK government has recently taken another step towards implementing the GloBE model rules by introducing to Parliament as part of Finance (No.2) Bill 2022/23 the second draft of legislation. This update builds on the first draft that was released in July 2022 and as expected introduces a new income inclusion rule through the multinational top-up tax which will require qualifying multinational groups to pay a top-up tax where their foreign entities have a jurisdictional effective tax rate of less than 15%. Notable additions to the draft legislation include provisions relating to the OECD guidance on safe harbours and penalty relief (published in December 2022) and OECD Administrative Guidance (published in February 2023). In addition a qualified domestic minimum top-up tax named the domestic top-up tax will be introduced which requires large groups including those operating exclusively in the UK ...

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.