Pillar 2: transitional country-by-country reporting safe harbour anti-arbitrage rule

This measure introduces an anti-arbitrage rule to counter arrangements designed to exploit differences between tax and accounting rules, as first announced in a Written Ministerial Statement.

The government has published draft legislation to consult on how the transitional safe harbour anti-arbitrage rule is legislated in the UK to ensure it operates as envisaged by the Organisation for Economic Co-operation and Development (OECD) G20 Inclusive Framework’s December 2023 Administrative Guidance.

To provide comments, please email: PillarTwoConsulatation@hmtreasury.gov.uk by 15 September 2024.