Is the UK Really Going to Go First?

The UK has been going through with respect to pillar to a consultation process. So they have already proposed some rules. There's not much wriggle room from a UK perspective to divert from the rules, or it wouldn't be a qualifying income inclusion rule which we went into the detail but has some adverse consequences in terms of certainty over the application of penalty. The UK HMRC Tax Authority and the UK Treasury have been having a number of working groups with advisors and taxpayers to take comments on some of the issues that have been identified with the rules. But then the UK is taking those away and then feeding them in to the OECD discussions that are taking place at the moment with the inclusive framework.