UK moves to implement OECD Pillar Two Side-by-Side package

The draft legislation updates the UK’s multinational and domestic top-up taxes legislation for recent OECD developments.

The United Kingdom (UK) Government, on 13 July 2026, released draft legislation which would both implement the Organisation for Economic Cooperation and Development (OECD) Pillar Two 'Side-by-Side' package and update other aspects of the UK's multinational and domestic top-up taxes legislation (which implements Pillar Two generally in the UK). The Side-by-Side package's safe harbours The draft legislation to implement the Side-by-Side package contains a series of new elective safe harbours:...

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Published Date: 27 July 2026