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Implications of Pillar 2 for multinational groups

12 February 2024 / Chris Danes , Steve Davies , Alex Lubbock
Issue: 4924 / Categories: Comment & Analysis , BEPS , multinationals , OECD , Compliance
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Multinational headache?

Key points

  • In the UK the Pillar 2 legislation came into effect on 1 January 2024.
  • New disclosure requirements in financial statements include having to list countries where a top-up tax is expected to arise.
  • Pillar 2 returns will have to be submitted which may need new software.
  • Three temporary safe harbours have been included in the OECD’s model rules but how beneficial will these be?
  • The main Pillar 2 headache is the compliance burden regarding multiple additional tax returns being due rather than paying over more tax.

Now that Pillar 2 has come into effect what actually are UK multinational groups focused on as they navigate their way through these new rules including meeting the increased tax compliance burden?

Background

Over recent years some multinational enterprises (MNEs) have been able to exploit gaps and mismatches in the tax rules of different countries to avoid paying tax. These tax...

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