Policy paper

Pillar 2: transitional country-by-country reporting safe harbour anti-arbitrage rule

This measure introduces the draft legislation for the transitional country-by-country reporting safe harbour anti-arbitrage rule.

• From: HM Revenue & Customs
• Published: 29 July 2024

Documents

Multinational top-up tax and domestic top-up tax — transitional country by country reporting safe harbour anti-arbitrage rule

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Draft legislation

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Draft legislation — accessible version

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Explanatory note

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Details

This measure introduces an anti-arbitrage rule to counter arrangements designed to exploit differences between tax and accounting rules, as first announced in a Written Ministerial Statement.

The government has published draft legislation to consult on how the transitional safe harbour anti-arbitrage rule is legislated in the UK to ensure it operates as envisaged by the Organisation for Economic Co-operation and Development (OECD) G20 Inclusive Framework’s December 2023 Administrative Guidance.

To provide comments, please email: PillarTwoConsulatation@hmtreasury.gov.uk by 15 September 2024.

Published 29 July 2024