United Kingdom: Announced draft for United Kingdom Implementation of Pillar Two

On 20 July 2022, the UK Treasury releases draft legislation for its implementation of the top-up tax envisioned by Pillar 2 of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). 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%. The rules would apply to covered enterprise groups with fiscal years starting on or after 31 December 2023.