Citation, commencement and effect

regulation 1 + 1.—(1) These Regulations may be cited as the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 and come into force on 21st April 2025.

(2) These Regulations have effect for accounting periods beginning on or after 31st December 2023.

Pillar Two territories

regulation 2 + 2.—(1) The territories set out in Schedule 1 are specified as Pillar Two territories with effect on and after the respective dates listed in the table.

(2) A territory is also a Pillar Two territory if it is specified as such in a notice published by the Commissioners for His Majesty’s Revenue and Customs.

Qualifying domestic top-up taxes

regulation 3 + 3.—(1) A Qualified Domestic Minimum Top-up Tax for the purposes of the Pillar Two rules that is charged by the territory listed, and under the legislation set out, in Schedule 2 is specified as a qualifying domestic top-up tax with effect on or after the respective date listed in the table.

(2) A Qualified Domestic Minimum Top-up Tax is also a qualifying domestic top-up tax if it is specified as such in a notice published by the Commissioners for His Majesty’s Revenue and Customs.

Accredited qualifying domestic top-up taxes

regulation 4 + 4.—(1) A Qualified Domestic Minimum Top-up Tax for the purpose of the Pillar Two rules that is charged by the territory listed, and under the legislation set out, in Schedule 3 is specified as an accredited qualifying domestic top-up tax with effect on or after the respective date listed in the table.

(2) A Qualified Domestic Minimum Top-up Tax is also an accredited qualifying domestic top-up tax if it is specified as such in a notice published by the Commissioners for His Majesty’s Revenue and Customs.

Schedules

Regulation 2

Schedule 1Pillar Two Territories

Regulation 3

Schedule 2Qualifying Domestic Top-up Taxes

Regulation 4

Schedule 3Accredited Qualifying Domestic Top-up Taxes

Explanatory Note

(This note is not part of the Regulations)

These Regulations specify territories as Pillar Two territories, and taxes as qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes, in support of the implementation and operation of the Organisation for Economic Co-operation and Development/G20 Inclusive Framework’s Pillar Two model rules.

Regulations 2, 3, and 4 have effect from a date before these Regulations commence. This is authorised by sections 241(3), 256(4) of, and paragraph 2(1C) of Schedule 16A to, the Finance (No. 2) Act 2023.

Regulations 2, 3, and 4 give effect to the Schedules which provide as follows:

• The table in Schedule 1 lists territories specified as Pillar Two territories along with the date from which they are specified as such,

• The table in Schedule 2 lists the taxes specified as qualifying domestic top-up taxes along with the date from which they are specified as such, and

• The table in Schedule 3 lists the qualifying domestic top-up taxes that are accredited for the purposes of an election in accordance with Schedule 16A to the 2023 Act along with the date from which they are so accredited.

Regulations 2, 3 and 4 also provide for Commissioners for His Majesty’s Revenue and Customs to specify further territories as Pillar Two territories, and taxes as qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes, by way of notice.

Public notices made under this instrument will be published on the website at https://www.gov.uk/government/collections/multinational-top-up-tax-and-domestic-top-up-tax.

Copies of the taxes specified in Schedule 2 and 3 are available for inspection in hard copy from 100 Parliament Street, London SW1A 2BQ and in electronic copy on request by emailing:

pillar2.consultation@hmrc.gov.uk.

A Tax Information and Impact Note covering this instrument will be published on the website at https://www.gov.uk/government/collections/tax-information-and-impact-notes-tiins.