Question to the HM Treasury:

To ask the Chancellor of the Exchequer, whether a disputes resolution mechanism agreed as part of the Organisation for Economic Cooperation and Development’s BEPS 2.0 Pillar 2 proposals would be binding upon UK courts.

The Government is delighted that more than 130 countries reached agreement on a Two-Pillar solution to the tax challenges arising from the digitalisation of the economy, on the 8 October 2021.

As outlined in the October 2021 Statement, the OECD will seek to develop an implementation framework by the end of 2022 which will be designed to facilitate the co-ordinated implementation and administration of the GloBE Rules.

Discussions on the implementation framework are ongoing and public input was recently sought on the issues that should be addressed as part of this work, including the question of whether mechanisms are needed to avoid the risk of double taxation: https://www.gov.uk/government/consultations/oecd-pillar-2-consultation-on-implementation.