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UK implementation of Pillar Two: where are we now?

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The UK has published the first draft of legislation to implement OECD BEPS Pillar Two into UK law. The draft UK rules impose a multinational top-up tax regime on qualifying multinational groups i.e. those operating in at least two jurisdictions and which have revenue which exceeds €750m in at least two out of the previous four accounting periods. As expected the UK has opted for a two-phase implementation with the income inclusion rule expected to come into force on 31 December 2023 and the under-taxed profits rule coming into force at a later date. In addition to rules on the scope of the charge the calculation of the top-up tax liability and when the liability becomes chargeable there are administrative provisions on enquiries assessment and penalties. The draft legislation is effectively a work in progress and contains numerous placeholders including on de minimis exemption...

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