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Policy Paper Published 4 Apr 2025 HM Revenue & Customs ↗ View on GOV.UK

The Multinational Top-up Tax (Pillar 2 territories, qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes) Regulations 2025

This tax information and impact note describes a Statutory Instrument being laid as part of the UK’s implementation of Pillar 2. This Instrument provides a list of Pillar 2 territories, qualifying domestic top-up taxes, and accredited qualifying domestic top-up taxes.

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Multinational Top-up Tax and Domestic Top-up Tax are the UK’s adoption of the Pillar 2 Global Anti-Base Erosion (GloBE) rules agreed by the UK and other members of the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework on base erosion and profit shifting.

This Instrument provides a list of:

  • territories that have implemented a qualifying income inclusion rule
  • taxes which are qualifying domestic top-up taxes (and the respective territories of those taxes)
  • taxes that are specified as being accredited for the qualifying domestic top-up tax safe harbour (and the respective territories of those taxes)