UK: HMRC can retrospectively designate Pillar Two territories, qualifying top-up taxes

Amendment to earlier regulations allowing HMRC to specify additional territories and taxes under UK Pillar Two rules

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September 24, 2025

Treasury on June 30, 2025, issued regulations SI 2025/783—effective July 24, 2025—empowering HM Revenue & Customs (HMRC) to retroactively designate “Pillar Two territories” and “qualifying top-up taxes” under the UK Pillar Two rules.

The regulations amend SI 2025/406, allowing HMRC to specify additional territories and taxes under the UK Pillar Two rules. Read TaxNewsFlash


For more information, contact a KPMG tax professional in the UK:

Qasim Javid | qasim.javid@kpmg.co.uk

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