Autumn Budget 2024 - International

Pillar Two

In October 2021, over 130 countries in the Inclusive Framework reached agreement on a two-pillar solution to reform the international tax framework in response to the challenges of digitalisation.

In Autumn Statement 2022, it was announced that the Multinational Top-up Tax and Domestic Top-up Tax would be introduced from accounting periods beginning on or after 31 December 2023 and the undertaxed profits rule from accounting periods beginning on or after 31 December 2024. Multinational Top-up Tax and Domestic Top-up Tax were introduced in Finance Act 2023.

A package of amendments to these taxes has been proposed. These amendments simply aim to ensure that the legislation works as was originally intended and is in line with OECD commentary. Of particular note the domestic top-up tax rules in Part 4, Finance (No.2) Act 2023 are being amended so that a UK Qualifying Asset Holding Company (QAHC) which is not a member of a multinational group will be an