Multilateral convention brings pillar one closer

If ratified by at least 30 jurisdictions, the convention will introduce a new mechanism for allocating taxing rights to market jurisdictions. The convention released by the OECD and G20 on 11 October 2023 relates specifically to ‘amount A’. This co-ordinates a reallocation of taxing rights to market jurisdictions with respect to a share of the […]

HMRC sends pillar two educational letters to large businesses

HMRC has started sending letters to large businesses who it believes may be within the scope of the UK’s new multinational top-up tax (MTT) and domestic top-up tax (DTT). The letters are intended to educate businesses about the new rules being introduced and allow them to clarify any issues in advance with HMRC. MTT and […]