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UK HMRC Consulting on Draft Guidance for Pillar 2 Global Minimum Tax Rules

20 June 2023

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Proposed Changes

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United Kingdom

UK HMRC has launched a public consultation on draft guidance for the Pillar 2 global minimum tax rules. As previously reported, the UK is implementing Pillar 2 rules as part of the Spring Finance Bill 2023, including: A multinational top-up tax that will require large UK headquartered multinational groups to pay a top-up tax where their operations in a foreign jurisdiction have an effective tax rate of less than 15%, which would also apply to non-UK headquartered groups with UK members that are partially owned by third parties or where the headquartered jurisdiction does not implement the Pillar 2 framework;...