On 27 September 2023, UK HRMC published an updated 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...