Comments are due by October 23, 2024.
HMRC on September 12, 2024, published additional draft guidance for consultation regarding the UK's Pillar Two global minimum tax rules.
This is the third version of draft HMRC guidance regarding the UK multinational top-up tax (MTT) and domestic top-up tax (DTT); previous draft versions were published in June 2023 and December 2023.
Comments on the guidance are due by October 23, 2024.
The draft guidance includes the new content regarding:
The updated draft guidance does not yet cover all of the provisions in the UK Pillar Two legislation and further supplemental guidance is expected later in the year. It is expected such guidance will address flow-through entities, joint ventures, the undertaxed profits rule (UTPR), tax equity partnerships, post-filing adjustments of covered taxes, and additional top-up amounts.
Read a September 2024 report prepared by the KPMG member firm in the United Kingdom