1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

  • 27 September 2023 – The UK government amended the legislation it had published in draft on July 18, 2023 to reflect the latest administrative guidance issued by the G20 and to reflect certain representations made by stakeholders.
  • July 18, 2023 – The UK government introduced legislation to adopt the UTPR and other amendments. The Multinational Top-up Tax and Domestic Top-up Tax in Finance (No.2) Act 2023 initially adopted the income inclusion rule and domestic minimum top-up tax rule.
  • July 11, 2023:UK Finance (No. 2) Act 2023 received Royal Assent, thus the GloBE rules have been adopted by the UK. The Finance Bill includes a “multinational top-up tax,” which implements the provisions of the Pillar Two rules related to top-up tax under the IIR. The Finance Bill also includes a “domestic top-up tax".
  • March 23, 2023: The UK published its Spring Finance Bill 2023, which legislates tax changes announced in its Budget.
  • November 17, 2022: In its Autumn Statement 2022, the UK government announced that it will legislate to introduce: (i) an Income Inclusion Rule and (ii) a Qualified Domestic Minimum Top-up Tax. These will be set  out in the Spring Finance Bill 2023. Additionally, the government indicated its intention to implement an Undertaxed Profits Rule, effective for accounting periods beginning on or after December 31, 2024.
  • July 20, 2022: Introduced Draft legislation and an explanatory note implementing certain measures under the OECD Pillar Two GloBE Model Rules

3. Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?

  • June 15, 2023: HMRC published for consultation, partial draft guidance on the proposed multinational top-up tax and domestic top-up tax. The consultation document provides additional information on which 
    groups of entities will be considered “in scope,” and how the taxes will be administered and charged.
  • December 21, 2023: HMRC published for consultation updated partial draft guidance on multinational top up tax and domestic top up tax. 

4. When will the Income Inclusion Rule (IIR) come into force?

2024.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

2025.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

2024.