UK Enacts New Multinational Top-Up Tax From December 31, 2023

The Finance (No. 2) Act, 2023 received Royal Assent on July 11, 2023. As such the UK legislation to give effect to the Income Inclusion Rule and a QDMTT is now enacted. The new Multinational Top-Up Tax applies to in-scope MNEs for accounting periods commencing on or after 31 December 2023. (Note that on July 18, 2023, the UK issued Draft Legislation for the UTPR.)

There were very few amendments to the original bill. The main additions were:

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