The Multinational Top-up Tax (Pillar Two Territories Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations SI 2025/406 set out the list of territories which have qualifying income inclusion rules and qualifying domestic top-up taxes to provide certainty for the purposes of the UK’s implementation of the Pillar Two minimum rate of tax. Multinational groups will be able to use these lists when calculating any top-up tax amounts that are due under the UK’s multinational top-up tax rules to make sure they are clear around which overseas taxes are ‘qualifying’ and can therefore be taken into account for the 15% minimum tax rate.
The regulations come into force on 21 April 2025 and have effect for accounting periods beginning on or after 31 December 2023. HMRC have published an accompanying Tax Information and Impact Note.
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The Multinational Top-up Tax (Pillar Two Territories Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations SI 2025/406 set out the list of territories which have qualifying income inclusion rules and qualifying domestic top-up taxes to provide certainty for the purposes of the UK’s implementation of the Pillar Two minimum rate of tax. Multinational groups will be able to use these lists when calculating any top-up tax amounts that are due under the UK’s multinational top-up tax rules to make sure they are clear around which overseas taxes are ‘qualifying’ and can therefore be taken into account for the 15% minimum tax rate.
The regulations come into force on 21 April 2025 and have effect for accounting periods beginning on or after 31 December 2023. HMRC have published an accompanying Tax Information and Impact Note.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
