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Review of the Pillar 2 Provisions in the UK Finance Bill 2024-2025

UK Enacts 2024 Finance Act to Implement the OECD Administrative Guidance

Contents
  1. Meaning of “ancillary” for Non-Profit Organisations
  2. Accrued Pension Expenses
  3. Tax Credits
  4. Substitute Loss Carry-Forwards
  5. Substance-Based Income Exclusion
  6. Qualifying CBC Reports
  7. Currency Rules
  8. Transitional Rules for Intragroup Transfers
  9. Transitional Reporting Election
  10. QDMTT Safe Harbour Election

On February 22, 2024, the UK Finance Act 2024 received Royal Assent. This  domestically implements amendments provided in the July 2023 OECD Administrative Guidance, includes some ancillary amendments from the February 2023 OECD Administrative Guidance and provides for other related changes.

The provisions in the Finance Act 2024, amend the Finance (No.2) Act 2023 (which implements the GloBE rules in the UK) and apply for accounting periods beginning on or after December 31, 2023.

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Picture of Lee Hadnum

Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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