UK: Amendments to Pillar Two rules in Finance Bill 2024-2025
Seeks to incorporate the undertaxed profits rule (UTPR) into UK domestic law
Finance Bill 2024-25 introduces amendments to the UK's existing Pillar Two rules as contained in the Finance (No.2) Act 2023.
The bill seeks to incorporate the undertaxed profits rule (UTPR) into UK domestic law, establish anti-arbitrage rules for transitional country-by-country (CbC) reporting safe harbors, and align UK legislation with the OECD’s Administrative Guidance on Pillar Two.
Read a November 2024 report prepared by the KPMG member firm in the UK