The Government published draft legislation and explanatory notes in July 2023 to implement the under-taxed profits rule (UTPR) as part of the UK's commitments to the OECD's Pillar Two international tax reforms. These draft clauses also introduced a range of other amendments to ensure the existing UK multinational top-up tax legislation in F(No 2)A 2023 remains consistent with the Global Anti-Base Erosion (GloBE) rules.
Amendments were made to this initial draft legislation in September 2023 and the legislation has been included in Finance Bill 2025 — see Tolley's Finance Bill Tracking Service, Finance Bill 2025, cl 19, Sch 4. The other amendments were included in Finance Act 2024, together with an additional raft of technical amendments.
The UTPR is one of two charging mechanisms within the multinational top-up tax regime. The primary charging mechanism, which is known internationally
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Web page updated on 17 Mar 2025 14:25