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The saga continues: implementing Pillar Two in the UK

The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and Jack Gifford (EY).

In the November 2022 Autumn Statement the chancellor announced that the government would introduce an income inclusion rule (IIR) and qualified domestic minimum top-up tax (QDMTT) as part of the Spring Finance Bill 2023. This followed nearly a year of consultation on various documents including the GloBE model rules accompanying commentary and the UK’s first draft of the proposed legislation on multinational top-up tax (MTUT). The various consultations triggered an abundance of technical and practical questions many of which could not be resolved unilaterally and required UK policy makers to undertake further work at Inclusive Framework. Notwithstanding that some issues are still unresolved many of the material issues were subsequently addressed as part of...

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