Regulations under the UK Pillar Two rules issued on March 31, 2025, provide the following lists of:
- Each jurisdiction specified as a “Pillar Two territory” under section 241 Finance (No.2) Act 2023, reflecting its implementation of a qualifying income inclusion rule, along with the date from which it is specified under the UK rules
- Each tax that is a “qualifying domestic top-up tax” under section 256 Finance (No.2) Act 2023 (and the respective jurisdictions with those taxes) along with the date from which it is specified under the UK rules
- Each qualifying domestic top-up tax that is specified as being “accredited” for the qualifying domestic top-up tax safe harbor in Schedule 16A to Finance (No.2) Act 2023 (and the respective jurisdictions with those taxes) along with the date from which it is so accredited under the UK rules
Read an April 2025 report prepared by the KPMG member firm in the UK