Multinational top-up tax: adoption of the undertaxed profits rule and other amendments
This measure includes the UK’s adoption of the backstop undertaxed profits rule and other amendments to keep UK legislation consistent with Global Anti-Base Erosion rules.
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This measure was updated on 27 September 2023 to include further amendments, including some affecting the Domestic Top-up Tax, to reflect the latest administrative guidance issued by the G20 — Organisation for Economic Co-operation and Development inclusive framework.
To provide any further comments, email PillarTwoConsultation@hmtreasury.gov.uk by 25 October 2023.
The government introduced the multinational top-up tax and domestic top-up tax in Finance (No.2) Act 2023. These taxes are the UK’s adoption of the income inclusion rule and domestic minimum top-up tax rule as referenced in the Pillar 2 Global Anti-Base Erosion (GloBE) rules.
The undertaxed profits rule ensures that any top-up taxes that are not paid under another jurisdiction’s Pillar 2 rules are brought into charge in the UK.
The other amendments ensure that UK legislation remains consistent with the agreed model rules, commentary and administrative guidance that have been agreed by the G20 — Organisation for Economic Co-operation and Development inclusive framework.
Further amendments may be introduced in the future to reflect subsequent administrative guidance released by the inclusive framework.
Updates to this page
Published 18 July 2023Last updated 27 September 2023 + show all updates
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This measure was updated to include further amendments, including some affecting the Domestic Top-up tax, to reflect the latest administrative guidance issued by the G20 — Organisation for Economic Co-operation and Development inclusive framework.
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First published.