UK Updates: Pillar Two is Coming
Cross-border Tax Talks
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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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