The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025
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.
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Lifecycle
Department
Made
27 Mar 2025
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In force
21 Apr 2025
Enabling power
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. 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.
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