Update your subscriptions for Grant Thornton publications and events.
-
Business Risk Services
Our Business Risk Services team deliver practical and pragmatic solutions that support clients in…
-
Corporate Finance and Deal Advisory
We offer a dedicated team of experienced individuals with a focus on successfully executing…
-
Economic Advisory
Our all-island Economics Advisory team combines expertise in economics and business with a…
-
Forensic Accounting
We have a different way of doing business by delivering real insight through a combination of technical…
-
People and Change Consulting
The Grant Thornton People & Change Consulting practice works with clients on these issues as well as on all…
-
Restructuring
We work with a wide variety of clients and stakeholders such as high street banks, private equity funds,…
-
Technology Consulting
Motivating and assisting our clients to pursue, maintain and secure the benefits of digital solutions is at the…
-
Corporate and International Tax
Northern Ireland businesses face further challenges as they operate in the only part of the UK that has a…
-
Employer Solutions
Our team specialises in remuneration and incentive planning and works closely with employers,…
-
Entrepreneur and Private Client Taxes
Our team of experienced advisors are on hand to guide you through any decision or transaction ranging…
-
Global Mobility Services
Grant Thornton Ireland offer a different approach to managing global mobility. We have brought…
-
Outsourced Payroll
Our outsourced service provides valued service to over 150 separate PAYE schemes. These ranging from…
-
Tax Disputes and Investigations
Our Tax Disputes and Investigation team is made up of tax experts and former HMRC investigators who…
-
VAT and Indirect Taxes
At Grant Thornton (NI) LLP, our team helps Northern Ireland businesses manage their UK and global…
As part of the Base Erosion and Profit Shifting (“BEPS”) project, the Organisation for Economic Cooperation and Development (“OECD”) has presented a two-pillar approach as an ongoing effort to reform international taxation and prevent tax avoidance by multinational enterprises (“MNEs”).
Pillar two focuses on establishing a global minimum tax rate to ensure that companies pay a minimum level of tax regardless of where they operate or where their profits are booked. The rules apply to MNEs with annual consolidated revenue of at least €750 million in at least two out of the prior four accounting periods.
The OECD provided details on two interlocking measures, the Income Inclusion Rule (“IIR”) and the Undertaxed Profits Rule (“UTPR”), whereby profits taxed at less than 15% would be targeted for additional taxation. The IIR imposes a top-up tax on the ultimate parent entity of a low-taxed foreign subsidiary. The UTPR seeks to deny deductions, or take similar actions, to collect tax that would otherwise not be collected under the IIR.
In response to this, the UK Government stated in the Autumn Statement that a qualified domestic minimum top-up tax (“QDMTT”) would be introduced in the UK alongside the IIR for accounting periods commencing on or after 31 December 2023. The QDMTT tax rule will require large groups, including those operating exclusively in the UK, to pay a top-up tax where their UK operations have an effective tax rate of less than 15%.
Both the multinational top-up tax and domestic top-up tax were formally introduced in the 2023 Finance Bill. The Government intends to implement the UTPR in the UK, but with effect no earlier than accounting periods beginning on or after 31 December 2024.
According to the OECD, Pillar Two represents “a radical shift in the tax landscape”. MNEs with global revenues of €750m or more will need to put measures in place to ensure they are compliant with Pillar Two, with MNEs that are close to the threshold being actively monitored. Failure to comply will result in penalties being imposed with interest accruing on any late paid top-up tax on a daily basis.
At Grant Thornton NI we have a dedicated international tax team and we work with a global network of international tax specialists who can advise and assist you and your business with planning to ensure compliance with the complex Pillar Two rules.