What is Pillar Two?
What is the UTPR top-up tax?
The Undertaxed Profits Rule (UTPR) is a secondary taxing rule designed to operate as a backstop to the Income Inclusion Rule. It applies when the ultimate parent entity is located in a non-implementing jurisdiction. The tax due under the UTPR is called UTPR top-up tax.
The UTPR came into effect for fiscal years commencing on, or after, 31 December 2024. There are certain limited circumstances where it may apply on, or after, 31 December 2023, but before 31 December 2024.
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