The Income Inclusion Rule and Qualified Domestic Minimum Top-Up Tax have been in force in the U.K., EU member states and other jurisdictions since December 31, 2023, with the Undertaxed Profits Rule following on December 31, 2024. Partner Jisun Choi and European counsel Kara Heggs discuss certain implications of these rules, particularly for commercial businesses and transactions.
Pillar Two One Year On: What Have We Seen and Where Are We Going?
Tax Journal