New global tax system

To tax multinational companies on business transactions completed in the UK, our government introduced the Digital Services Tax (DST) April 2020.

The US response was to threaten to levy tariffs. However, a compromise has been reached that will see the introduction of a global system that will ensure multinationals do pay their fair share of tax in the countries where they do business.

This new global system will be introduced in 2023.

On 8 October 2021, OECD-led discussions resulted in 136 countries agreeing a plan for a new system (known as Pillar One), whilst countries will also operate a minimum 15% corporation tax rate (known as Pillar Two).

As part of this agreement the US will not levy tariffs in response to the UK’s DST. The UK will also keep the revenue raised from the DST until the Pillar One reforms become operational. The DST credit agreement outlines that once Pillar One is in effect, firms will be able use the difference between what they have paid in DST from January 2022, and what they would have paid if Pillar One had been in effect instead, as credit against their future corporation tax bill.

This means that the UK will not lose out on tax revenue in the transition period, as for each business, the UK either retains the amount raised that Pillar One would have delivered if it had been in place originally, or the total revenue from our DST.

The DST will then be removed in favour of the global solution, which was always the UK’s intention.

Details in a recent press release confirm:

  • The agreement signed is between the US, UK, France, Italy, Austria, and Spain.
  • Under Pillar One of the OECD agreements, the largest and most profitable multinationals will be required to pay tax in the countries where they operate – and not just where they have their headquarters.
  • The rules would apply to global firms with at least a 10% profit margin – and would see 25% of any profit above the 10% margin reallocated and then subjected to tax in the countries they operate. Pillar 1 will be implemented through a Multilateral Convention (MLC) with this aiming to come into effect in 2023.

Under Pillar Two, the G7 also agreed to implement a 15% global minimum corporation tax, aiming to become effective from 2023. This will be operated on a country-by-country basis, creating a more level playing field for UK firms and cracking down on tax avoidance.

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