The international nature of large businesses presents high risks to tax revenues, including from profit shifting. Nearly 90% of large businesses operate internationally and of the £70.1 billion of tax under consideration in 2025 as part of investigations into large businesses, HMRC estimates around £21 billion relates to international risks, including profit shifting.37 The UK is working with other countries within the OECD to address these challenges. A key measure is the Pillar 2 agreement, which introduced a global minimum 33 Letter from HMRC to the Committee dated 3rd June 2026 34 Qq 45-51 35 C&AG’s Report, para 1.4 36 Q 51 37 Q 51, C&AG’s Report, para 1.4 14 effective corporate tax rate of 15% for large multinational businesses. The UK has adopted Pillar 2, with UK large businesses liable to pay top-up taxes to hit the minimum rate wherever they operate.38