The UK’s implementation of OECD Pillar 2 rules

Key points

• The UK government estimates that Pillar 2 could raise £2.2bn a year by 2027-28.
• A revised version of the original commentaries to the GloBE rules is expected to be released later this year.
• The ‘multinational top-up tax’ is designed to apply to multinational enterprises that operate in at least two jurisdictions with revenues exceeding €750m in at least two of the previous four accounting periods.

The UK remains on a fast track to implement the G20 global anti-base erosion (GloBE Pillar 2) rules developed by the Organisation for Economic Co-operation and Development (OECD) into domestic laws. The impact of the GloBE rules is significant. The International Monetary Fund estimates that Pillar 2 will raise global corporate tax revenues by 5.7%. The UK government estimates that Pillar 2 could raise £2.2bn a year by 2027-28.

Tax savings from low-tax business structures are expected to decline once (and...