The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.
In July Finance (No. 2) Act 2023 (F(No.2)A 2023) implemented into UK tax law the income inclusion rule (IIR) aspects of the OECD’s Pillar Two model rules (the ‘OECD Pillar Two rules’).
Draft legislation for the UK’s implementation of the undertaxed profits rule aspects of those rules (UTPR) has also recently been published (see Multinational top-up tax: adoption of the undertaxed profits rule and other amendments at bit.ly/mntop-uptax).
The resultant multinational top-up tax (MTT) regime will be endlessly complicated.
Accordingly the following paragraphs explore ten key aspects of that regime highlighting statutory provisions that are essential to its operation.
Unless otherwise stated all section references are to F(No.2)A 2023.
1....
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The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.
In July Finance (No. 2) Act 2023 (F(No.2)A 2023) implemented into UK tax law the income inclusion rule (IIR) aspects of the OECD’s Pillar Two model rules (the ‘OECD Pillar Two rules’).
Draft legislation for the UK’s implementation of the undertaxed profits rule aspects of those rules (UTPR) has also recently been published (see Multinational top-up tax: adoption of the undertaxed profits rule and other amendments at bit.ly/mntop-uptax).
The resultant multinational top-up tax (MTT) regime will be endlessly complicated.
Accordingly the following paragraphs explore ten key aspects of that regime highlighting statutory provisions that are essential to its operation.
Unless otherwise stated all section references are to F(No.2)A 2023.
1....
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
