On November 7, 2024, the UK issued Finance Bill 2024-2025 which includes a number of amendments to provide for the December 2023 and June 2024 OECD Administrative Guidance. Read our updated GloBE Guide.
On November 7, 2024, the Finance Bill 2024-2025 was introduced to Parliament. This includes provisions to enact the UTPR (and associated rules such as the Transitional UTPR Safe Harbour and Initial Phase of International Activity Exemption), and other Pillar 2 amendments.
The UK 2024 Budget on October 30, 2024 confirmed a number of proposed amendments to the application of the Pillar Two GloBE rules including a provision for a foreign QDMTT to qualify for the QDMTT Safe Harbour if it is reasonable to conclude that it is likely to fall within the OECD guidance. Read our updated UK GloBE Guide for more information.
On September 12, 2024, the UK issued further draft guidance on the Multinational Top-up Tax and Domestic Top-up Tax. The issued draft guidance now runs to over 300 pages.
On July 29, 2024, the UK government issued draft legislation for the implementation of the Pillar Two anti-avoidance rules targeting Hybrid Arbitrage Arrangements.
On March 14, 2024, the UK Government confirmed it is to apply an anti-avoidance rule for the purposes of the Transitional CbcR Safe Harbour from March 14, 2024.
On February 22, 2024, the UK enacted the 2024 Finance Act to domestically implement amendments provided in the OECD Administrative Guidance.
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