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UK: Pillar Two tax measures in Autumn Budget 2024

Undertaxed profits rule (UTPR) will be included in the Finance Bill 2024-2025

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October 31, 2024

The Chancellor on October 30, 2024, delivered the Autumn Budget 2024, which includes the following measures relating to the UK Pillar Two global minimum tax rules:

  • The government will implement the undertaxed profits rule (UTPR) in the Finance Bill 2024-2025 for accounting periods beginning on or after December 31, 2024.
  • Various technical amendments to the existing UK multinational and domestic top-up tax legislation will also be included in Finance Bill 2024-2025 to incorporate latest international updates and inputs from stakeholder consultation, with most of these applying for accounting periods beginning on or after December 31, 2024, but some effective for accounting periods beginning on or after December 31, 2023.
  • The government confirmed its intention to implement anti-arbitrage rules in respect of the transitional country-by-country (CbC) reporting safe harbors effective from March 14, 2024.

Read an October 2024 report prepared by the KPMG member firm in the United Kingdom

For more information, contact a KPMG tax professional:

Tim Sarson | tim.sarson@kpmg.co.uk

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