15% global minimum tax: technical adjustments in the 2026 Finance Act

Articles 104 and 105 of the 2026 Finance Act adjust the global minimum tax rules for large groups (Pillar Two): categories of deferred tax liabilities and recapture of those not reversed within five years, exemption of listed investment entities from the domestic top-up tax, designation of a liable entity for the under-taxation of investment entities and securitisation vehicles, transposition of OECD administrative guidance (flow-through and hybrid entities, securitisation arrangements, reallocation of deferred taxes, joint ventures) and the option for the tax authorities to request a corrected information return. Depending on the provision, they apply to financial years ending after publication of the law or beginning on or after 31 December 2023.