37. OECD Pillar Two

That provision may be made—

(a) imposing a tax for the purpose of implementing the OECD Pillar Two model rules (Tax Challenges Arising from Digitalisation of the Economy – Global Anti-Base Erosion Model Rules) so far as they relate to the charging of a top-up tax under the income inclusion rule (within the meaning of those rules), and

(b) imposing a tax for purposes in connection with implementing a Qualified Domestic Minimum Top-up Tax within the meaning of those rules.