On 20 July 2022, the UK government released the draft legislation on the Pillar 2 Income Inclusion Rule (IIR) along with its response to the public consultation on the UK implementation of Pillar 2. The draft legislation is intended to be introduced in Finance Bill 2022-23 (expected to receive royal assent in early 2023) and will apply to accounting periods commencing on or after 31 December 2023 (which is aligned with the proposed EU implementation).
In the consultation response, the UK government reiterated their view that the UK implementation of Pillar 2 rules should closely follow the OECD model rules. In areas where there is currently ambiguity, the UK intends to seek for resolution by working with its international partners as part of the OECD Implementation Framework to best ensure international consistency.
The response has also provided an opportunity for the UK government to share their position on the following key areas:
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