UK draft legislation for Pillar Two

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.

Draft Legislation for the Hybrid Arbitrage Arrangement Anti-Avoidance Rule

Draft Guidance – September 2024

On July 18, 2023, the UK issued draft legislation to implement the UTPR.  The UK 2024 Budget confirmed the UTPR will apply from 2025 (as well as various other amendments).

Finance Bill 2024-2025 issued on November 7, 2024

On November 30, 2024, the UK issued guidance on how and when to pay Pillar 2 top-up tax.
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. The Transitional UTPR Safe Harbour is included in the Finance Bill 2024-2025

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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