Group Tax Strategy and OECD Pillar Two: UK Multinational Top-up Tax, MAP and Tax Governance

Strategic international tax for UK group heads of tax and CFOs: OECD Pillar Two GloBE rules and the UK Multinational Top-up Tax and Domestic Top-up Tax (Finance (No.2) Act 2023), group tax consolidation and loss utilisation via UK Group Relief (CTA 2010), international tax disputes and Mutual Agreement Procedures, group restructuring strategies including post-Brexit cross-border mergers, and tax governance obligations including Senior Accounting Officer certification, public tax strategy publication, and the BRR+ cooperative compliance framework. Grounded in Finance (No.2) Act 2023, OECD Pillar Two guidance, TIOPA 2010, and HMRC published frameworks.