UK Tweaks Global Minimum Tax Exclusions, Calculation Rules

The UK amended its rules around implementation of the global minimum tax to further define excluded entities and determine when top-up charges are made.

His Majesty’s Revenue and Customs clarified parts of its legislation establishing a minimum corporation tax of 15% for large multinationals Thursday allowing permanent establishments to qualify as excluded entities when a main entity doesn’t have an ownership in the establishment.

Excluded entities aren’t in scope for the calculation of the Global Anti-Base Erosion model rules, known as Pillar Two of the Organization for Economic Cooperation and Development’s global tax deal.

• HMRC said in its ...