UK HRMC has published a policy paper, Multinational top-up tax: adoption of the undertaxed profits rule and other amendments. The policy paper covers a measure to amend the recently enacted Finance (No.2) Act 2023 for the introduction of the Pillar 2 undertaxed profits rule (UTPR) into UK legislation. The Finance (No.2) Act 2023 introduced a multinational top-up tax (income inclusion rule) and a supplementary domestic top-up tax that will take effect in relation to accounting periods beginning on or after 31 December 2023. The proposed UTPR is proposed to take effect no earlier than accounting periods beginning on or after...