Pillar Two one year on: what have we seen and where are we going?

The Income Inclusion Rule (IIR) and Qualified Domestic Minimum Top-up Tax (QDMTT) have been in force since 31 December 2023 in the UK all Member States of the EU and beyond. The Undertaxed Profits Rule (UTPR) came into effect from 31 December 2024 in those same jurisdictions with other jurisdictions introducing an IIR a QDMTT or both and in some cases an entirely new corporate income tax regime designed to act as a defence against the incoming UTPR.

Notably however the US has not implemented Pillar Two whether the IIR or a QDMTT (at least not in a form consistent with the OECD’s model GLoBE (Global Anti-Base Erosion) rules) and it appears abundantly clear to pundits in...