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Pillar Two compliance: the view from the 100 Group Tax Committee

Writing on behalf of the 100 Group Tax Committee, Dominic Mathon reports views from the Committee's members on how much additional tax they expect to pay as a result of Pillar Two - and the associated compliance costs. 

The UK formally adopted the OECD’s Pillar Two or so-called ‘minimum tax’ regime in Finance (No. 2) Act 2023. The purpose of this article is not to discuss the detailed rules or the many unanswered questions that abound. For that see for example ‘Multinational top-up tax: an overview’ (M Mortimer and T Ruiz) Tax Journal 11 September 2023. Instead this article looks at the implications of those rules for UK PLC or to be more specific the implications for the largest PLCs in the UK.

Background

The OECD’s Base Erosion and Profit Shifting (BEPS) initiative arose out of a widespread perception that companies and...

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