On 11 January 2022, the United Kingdom (UK) launched a public consultation seeking input on the domestic implementation and administration of the newly released model rules on the OECD-led global anti-base erosion (GloBE) proposal under Pillar Two.
The public consultation, particularly, seeks feedback on the following:
- how the model rules should be translated into UK legislation;
- how the model rules should be administered; and
- what implementation issues may ensue that should be addressed in the envisaged implementation framework.
Additionally, the consultation seeks public input on the introduction of a UK domestic minimum tax (DMT), as well as on a wider reform to the existing UK Base Erosion and Profit Shifting (BEPS) legal framework.