GloBE Country Guide: The United Kingdom

Summary

Status	Enacted Law
Law	Finance (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 Draft Legislation for the Hybrid Arbitrage Arrangement Anti-Avoidance Rule Draft Guidance – September 2024 On July 18, 2023, the UK issued draft legislation to implement the UTPR.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 December 19, 2024, the UK issued amendments to the Finance Bill 2024/2025 which includes amendments for the June 2024 OECD Administrative Guidance. On November 30, 2024, the UK issued guidance on how and when to pay Pillar 2 top-up tax.
Effective Date	Accounting periods beginning on or after 31 December 2023
IIR	Yes (2024)
UTPR	Proposed for accounting periods beginning on or after 31 December 2024.
QDMTT	Yes
Filing Deadlines	Standard
Safe Harbours	Yes, 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

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties
UK Law Mapped to OECD Model Rules

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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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