Part 3Multinational top-up tax
Chapter 10Definitions etc
Miscellaneous
255Pillar Two rules
1
In this Part references to the “Pillar Two rules” are to the Pillar Two model rules as interpreted in accordance with, and supplemented by—
a
the Pillar Two commentary, and
b
any further commentaries or guidance published from time to time by the OECD that are relevant to the implementation of the Pillar Two model rules.
2
In subsection (1)—
“Pillar Two model rules” means the model rules published by the Organisation for Economic Co-operation and Development as “Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS”;
“Pillar Two commentary” means the following—
- a
the commentary on the Pillar Two model rules published by the Organisation for Economic Co-operation and Development as “Tax Challenges Arising from the Digitalisation of the Economy – Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two)”, and
- b
the examples illustrating the application of the Pillar Two model rules published by the Organisation for Economic Co-operation and Development as “Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two) Examples”.
- a
3
Pillar Two rules apply to a multinational group, or a member of a multinational group, in an accounting period if—
a
the group is a qualifying multinational group, or
b
the group would be a qualifying multinational group but is not only as a result of Condition B in section 129(3) (requirement that at least one member located in the United Kingdom).