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Development of the Pillar 2 legislation in the UK

Signatories to the OECD/G20 Statement on the two-pillar approach referred to in D4.301 above, including the UK, must implement local legislation in order to give effect to the GloBE Model Rules. As local laws will be required separately in each territory, the rules will come into effect at different times globally and progress will need to be monitored by MNEs.

In January 2022, the UK Government launched a consultation on the UK's implementation and administration of the Pillar Two regime in response to the publication of the OECD's Model Rules. It is intended that the UK's Pillar Two rules are as close as possible to the OECD Model Rules in order to minimise the possibility of double taxation or double non-taxation that could arise where different countries adopt different rules.

In July 2022, the UK