Paragraph 32 Qualifying undertaxed profits tax
United Kingdom
(1)
For the purposes of Part 3 of F(No.2)A 2023, a tax is to be treated as a qualifying undertaxed profits tax for any accounting period that ends before the first regulations under section 257 of that Act have been made if—
(a)
it is a Qualified UTPR for that accounting period for the purposes of the Pillar Two rules, or
(b)
it is reasonable to conclude that it is likely to be a Qualified UTPR for that accounting period for the purposes of the Pillar Two rules.
(2)
In sub-paragraph (1) “Pillar Two rules” has the same meaning as in Part 3 of F(No.2)A 2023 (see section 255 of that Act).