Policy paper

Pillar 2: adoption of the undertaxed profits rule

This tax information and impact note describes the UK’s adoption of the undertaxed profits rule.

• From: HM Revenue & Customs
• Published: 30 October 2024

Documents

Multinational Top-up Tax — undertaxed profits rule

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The UK 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 Pillar 2 Global Anti-Base Erosion rules. This measure extends those taxes to give effect to the undertaxed profits rule.

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.

Published 30 October 2024