Measures affecting Large Corporates proposed during the Autumn Budget 2024 mainly centered around the Multinational Top Up Tax, the Common Reporting Standard and Cryptoasset Reporting Framework (CARF).
Details of the following measures and consultations were published in the Autumn Budget 2024.
Transfer pricing
Effective for all chargeable periods from the introduction of TIOPA 2010:
- HMRC is correcting a technical gap in the legislation that, contrary to Statement of Practice 1 (2012), meant APAs could not be entered in cases where the UK transfer pricing rules were only in point due to the acting together provisions.
Multinational Top-up Tax and Domestic Top-up Tax
Amendments apply mainly take effect for accounting periods beginning on or after 31 December 2024, some provisions apply for periods beginning on or after 31 December 2023.
- Part 3 and Part 4 of Finance (No.2) Act 2023 will be amended to facilitate the effective implementation of the GloBE rules, commentary and administrative guidance as these continue to evolve
Multinational Top-up Tax: Undertaxed Profit rule
Measures effective for accounting periods beginning on or after 31 December 2024:
- The undertaxed profits rule ensures that any top-up taxes that are not paid under another jurisdiction’s Pillar 2 rules are brought into charge in the UK.
- Part 3 of Finance (No. 2) Act 2023 will be amended to implement the undertaxed profits rule.
- Chapter 2 of Part 3 will be amended to include the undertaxed profits rule within the charge to Multinational Top-up Tax.
- Chapter 9A will be added to Part 3, to set out the rules required to calculate the additional tax due under the undertaxed profits rule.
- Chapter 3 will be added to Part 3 of Schedule 16 to provide for the undertaxed profits rule transitional safe harbour election.
- Schedule 16A will be amended to exclude the profits of groups in the initial phase of international expansion.
Common Reporting Standard: International Tax Compliance Regulations
- A consultation was launched during Autumn Budget 2024 seeking views on implementing the new rules of the Organisation for Economic Co-operation and Development amendments to the Common Reporting Standard and certain other proposals. The draft regulations set out further details of:
- A mandatory registration requirement for financial institutions.
- The conditions for non-profit organisations to be taken out of scope.
- Revised penalties for failing to comply with the regulations and the appeals process.
- Penalties for failure to provide a valid self-certification.
These draft regulations will be of interest to:
- Financial institutions and third-party service providers.
- Organisations and bodies that represent financial institutions or their advisors.
- Holders of financial accounts and the controlling persons of entity account holders.
The government is seeking technical feedback on the draft regulations to ensure they operate as the government intends and to identify any areas that need further clarification. If you identify any issues for financial institutions operating the revised rules set out in the draft amended regulations, please email
This email address is being protected from spambots. You need JavaScript enabled to view it. by 10 January 2025.
Cryptoasset Reporting Framework and Common Reporting Standard
The Cryptoasset Reporting Framework (CARF) and amendments to the Common Reporting Standard (CRS2) are the latest AEOI package designed to close gaps in existing transparency rules created by developments in fintech.
The CARF is a wholly new standard that addresses tax non-compliance using cryptoassets and CRS2 is an update to the existing framework on offshore accounts. Following public consultation at the OECD, the rules and commentary for the package have been agreed but the practical implementation is not prescribed in detail.
The draft regulations set out further details of:
- Reporting and due diligence requirements for reportable cryptoasset service providers (RCASPs) to comply with the CARF.
- Penalties for failing to comply with the regulations and appeals process.
- The requirement for cryptoasset users to provide a valid self-certification.
- Penalties for failure to provide a valid self-certification.
These draft regulations will be of interest to:
- RCASPs which facilitate the provision of cryptoassets and transactions with cryptoassets.
- Organisations and bodies that represent RCASPs or their advisors.
- Cryptoasset users.
The government is seeking technical feedback on the draft regulations to ensure they operate as the government intends and to identify any areas that need further clarification in more detailed guidance. If you identify any issues for cryptoasset service providers operating under the new UK; please email;
Useful guides on this topic
Autumn Budget 2024: At a glance
Our At a glance view to the Autumn Budget 2024
Our Autumn Budget 2024: Live Speech highlights
Our live feed summary of the highlights of the Chancellor's Autumn Budget speech.
