The Income Inclusion Rules and Undertaxed Payment Rules proposed by the OECD under ‘Pillar Two’ of their Inclusive Framework Project are not yet in force. The UK government has indicated it intends to bring forth legislation to enact the rules – collectively known as the ‘GloBE rules’ – in 2022, with the UK commencement of the Income Inclusion Rule (IIR) for accounting periods beginning on or after 31 December 2023 – i.e. effectively from 1 January 2024.

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