Autumn Statement 2023: Large corporates

The Chancellor announced the following measures on large corporates in his 2023 Autumn Statement.

Pillar 2: Undertaxed Profits Rule (UTPR)

For accounting periods beginning on or after 31 December 2024: 

• Legislation will amend the multinational top-up tax to introduce the Undertaxed Profits Rule (UTPR).
• This is the backstop rule in Pillar 2, an international agreement to help tackle profit shifting and aggressive tax planning by multinationals.

Pillar 2: multinational top-up tax and domestic top-up tax amendments

For accounting periods beginning on or after 31 December 2023:

• Legislation will be introduced in Autumn Finance Bill 2023 to amend the Multinational Top-up Tax and Domestic Top-up Tax which were introduced in Spring Finance Bill 2023.
  • This follows the publication of draft legislation on 18 July and 27 September 2023.
  • These taxes are the UK’s adoption of Pillar 2, an international agreement to help tackle profit shifting and aggressive tax planning by multinationals.
• The amendments reflect recent internationally agreed guidance and clarify areas identified from stakeholder consultation. 

Repeal of Offshore Receipts in respect of Intangible Property (ORIP)

For income arising from 31 December 2024:

• Legislation will repeal the Offshore Receipts in respect of Intangible Property (ORIP) rules.

Electricity Generator Levy: new investment exemption

From 22 November 2023:  

• An exemption from the Electricity Generator Levy for receipts from new electricity generating stations will be introduced.
• New electricity generating stations will include new standalone stations and substantial expansions and repowering of existing stations.
• This measure will take effect for revenues from new electricity generating stations where the substantive decision to invest is taken on or after 22 November 2023.

Useful links

Autumn Statement 2023: At a glance
The Chancellor, Jeremy Hunt, presented his Autumn Statement 2023 speech on Wednesday 22 November. This is our 'At a glance' summary of the key tax announcements and measures. 

External links

Policy paper: Multinational top-up tax and domestic top-up tax — amendments