Statutory Instruments
2025 No. 406
DOMESTIC TOP-UP TAX
MULTINATIONAL TOP-UP TAX
The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025
Made
27th March 2025
Laid before the House of Commons
31st March 2025
Coming into force
21st April 2025
The Treasury make these Regulations in exercise of the powers conferred by sections 241 and 256 of, and paragraph 2 of Schedule 16A to, the Finance (No. 2) Act 2023(1).
The Treasury consider, in relation to territories that are specified as Pillar Two territories, that provisions implementing the Pillar Two rules relating to top-up tax under the IIR (within the meaning of those rules) have effect under the law of those territories, or will have effect on or before the date on which the specification has effect.
The Treasury consider, in relation to taxes that are specified as qualifying domestic top-up taxes, that those taxes are equivalent in substance to domestic top-up tax under Part 4 of the Finance (No. 2) Act 2023.
2023 c. 30; Section 241 was amended by paragraphs 8 and 51(1) of Schedule 4 to the Finance Act 2025 (c. 8). Section 256 was amended by paragraph 51(2) of Schedule 4 to the Finance Act 2025. Paragraph 2 of Schedule 16A was inserted by paragraph 41(1) of Schedule 12 to the Finance Act 2024 (c. 3) and amended by paragraph 51(3) of Schedule 4 to the Finance Act 2025.