GloBE Country Guide: The United Kingdom

Summary

Status Enacted Law
LawFinance (No. 2) Act, 2023 (2023 Spring Finance Act) of July 11, 2023

Finance Act, 2024 of February 22, 2024.

On May 20, 2024, the UK issued a Pillar 2 top-up taxes registration notice, that  explains how to register for Pillar 2 top-up taxes in the UK, the information required and how to notify HMRC of any reporting related changes.
Effective DateAccounting periods beginning on or after 31 December 2023
IIRYes (2024)
UTPRProposed for accounting periods beginning on or after 31 December 2024.
QDMTTYes
Filing DeadlinesStandard
Safe HarboursYes, Transitional CbCR Safe Harbour (anti-avoidance rules targeting Hybrid Arbitrage Arrangements to apply from March 14, 2024) and the QDMTT Safe Harbour.

Contents
  1. Legislation
  2. General
  3. Differences to Model Rules
  4. Qualifying Domestic Minimum Top-Up Tax
  5. Administration and Filing
  6. Penalties
  7. UK Law Mapped to OECD Model Rules

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