Question to the HM Treasury:

To ask the Chancellor of the Exchequer, with reference to the consultation on implementation of OECD Pillar 2 published 11 January 2022, and the statement in paragraph 3.6 that the effectiveness of the global rules also depends on a high degree of consistency in the implementation in different jurisdictions, what assessment his Department has made of the progress being made towards the consistent implementation of the rules in the United States; and if he will make a statement.

The international group representing more than 135 countries that are collaborating to tackle tax avoidance (known as the ‘Inclusive Framework’) have agreed that Pillar 2 implementation is subject to a ‘common approach’. This means that countries that implement Pillar 2 must do so in line with the intended outcomes of the rules, ensuring consistency in implementation. A qualification process for each country that implements Pillar 2 is under discussion by the Inclusive Framework.

The United States have already implemented a tax on low taxed foreign profits called Global Intangible Low Taxed Income (GILTI). The Government recognises that the US has committed to reforming the GILTI rules so that they align with the Pillar 2 rules. How GILTI and Pillar 2 will interact, pending such reform, is being agreed internationally.