UK Introduces Multinational and Domestic Top-up Tax Rules Under OECD Pillar Two

The UK has implemented two new tax measures aligned with the OECD’s Pillar Two framework. Multinational Top-up Tax applies the Income Inclusion Rule and Undertaxed Profits Rule to international groups, whilst Domestic Top-up Tax extends equivalent minimum tax requirements to UK-based entities. Both measures aim to ensure larger businesses pay a minimum level of tax on their profits.

Source: HMRC (GOV.UK) – Read the original