Schedule 8 Pillar Two

United Kingdom

1. 1Introduction
2. 2Application of the income inclusion rule to cases involving permanent establishments
3. 3Application of the income inclusion rule to cases involving permanent establishments
4. 4Elective qualifying domestic top-up taxes
5. 5Elective qualifying domestic top-up taxes
6. 6Other provision about permanent establishments
7. 7Other provision about permanent establishments
8. 8Other provision about permanent establishments
9. 9Other provision about permanent establishments
10. 10Intragroup accounting discrepancies
11. 11Tax-transparent investment entities: double counting
12. 12Adjustments for ultimate parent that is a flow-through entity
13. 13Qualifying current tax expense
14. 14Qualifying current tax expense
15. 15Qualifying current tax expense
16. 16Intragroup transactions
17. 17Intragroup transactions
18. 18Tax equity partnerships: calculation of excess return for clawback
19. 19Cross-border allocation of deferred tax assets and liabilities
20. 20Deferred tax assets and liabilities: exclusions
21. 21Deferred tax assets and liabilities: exclusions
22. 22Deferred tax assets and liabilities: exclusions
23. 23Post-filing adjustments of covered taxes
24. 24Securitisation companies
25. 25Securitisation companies
26. 26Location of stateless entities
27. 27Location of stateless entities
28. 28Qualifying undertaxed profits tax
29. 29Qualifying undertaxed profits tax
30. 30Qualifying undertaxed profits tax
31. 31Qualifying undertaxed profits tax
32. 32Qualifying undertaxed profits tax
33. 33Definition of “ownership interest”
34. 34REITs: domestic top-up tax
35. 35Domestic top-up tax: exchange rates
36. 36Domestic top-up tax: covered tax to include group relief payments
37. 37Domestic top-up tax: covered tax to include group relief payments
38. 38Domestic top-up tax: allocation of CFC mobile income
39. 39Simplified calculations for non-material members
40. 40Minor amendments
41. 41Minor amendments
42. 42Minor amendments
43. 43Minor amendments
44. 44Minor amendments
45. 45Minor amendments
46. 46Minor amendments
47. 47Minor amendments
48. 48Minor amendments
49. 49Minor amendments
50. 50Minor amendments
51. 51Minor amendments
52. 52Minor amendments
53. 53Commencement