Last week HMRC launched the consultation above to look at how they will implement the OECD proposals (Pillar 2).
The Pillar 2 rules are part of the remaining work of the OECD Base Erosion Profit Shifting (BEPS) initiative, originally initiated in 2012, many of the proposed actions of which were published in 2015 and which have already been introduced in the UK, and many other countries around the world.
BEPS was initiated to find ways to counter international tax avoidance, and the latest proposals for a Corporate Minimum Tax will help provide mechanisms for countries where resident companies are shifting profits to low and zero rate countries, to tax part of those profits. The proposed effective Minimum Corporate Rate is 15%.
Interestingly, the UK government is also proposing a Domestic Minimum Rate, as part of their implementation proposals to help ring fence taxes into the UK.
Summary In line with the agreement on a two Pillar solution to reform the international tax system, the government will publish a consultation on how the Pillar Two rules will be implemented in the UK. This consultation closes at 11:45pm on 4 April 2022