UK HMRC has published a policy paper on draft legislation to implement the transitional Country-by-Country reporting safe harbour anti-arbitrage rule. --- General description of the measure Multinational Top-up Tax and Domestic Top-up Tax are the UK's adoption of the income inclusion rule and domestic minimum top-up tax rule in the Global Anti-Base Erosion (GloBE) Rules agreed by the UK and other members of the Organisation for Economic Co-operation and Development (OECD) G20 Inclusive Framework on base erosion and profit shifting. The OECD Inclusive Framework became aware of avoidance transactions that were designed to exploit differences between the tax and accounting...