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.
Documents
Details
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.