1min chapter

Cross-border Tax Talks cover image

UK Updates: Pillar Two is Coming

Cross-border Tax Talks

CHAPTER

The Under-Tax Profit Rule

The income inclusion rule, so for UK-parented groups, any subsidiaries below the UK would be subject to these PILOTY top-up tax rules. The earliest it will be introduced is 31 accounts in periods commencing on or after 31 December 2024. So a definite year gap, but as we said, it's the earlier, so potentially a later start date.

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