On 31 December 2023, the UK implementation of the top-up tax envisioned by Pillar 2 of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) included in the Finance (No. 2) Bill began to apply to covered enterprise groups. As agreed in the Inclusive Framework, the tax will apply to parent members of a multinational enterprise group if a subsidiary located in another jurisdiction is taxed at below 15%.
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