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UK publishes legislation for multinational top-up tax and domestic top-up tax

27 March 2023

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Tax Alerts, Legislation & Policy, National/Federal Taxation, OECD, BEPS 2.0

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United Kingdom

The UK has published legislation to implement the OECD GloBE Pillar Two rules in the UK. The legislation is expected to be enacted in summer 2023.The legislation builds on draft legislation already published but adds a number of key developments.Executive summaryThe UK’s Finance (No.2) Bill 2023, published on 23 March 2023, includes the legislation to implement the Organisation for Economic Co-operation and Development (OECD) Global Anti-Base Erosion (GloBE) Pillar Two rules in the United Kingdom (UK).The legislation covers the multinational top-up tax (MTUT), which includes the GloBE calculation and income inclusion rule (IIR), as well as a domestic top-up tax...