UK: Updated list of Pillar Two territories, qualifying top-up taxes

13 more territories added to list of territories with qualifying income inclusion rules and of qualifying domestic top-up taxes

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October 30, 2025

HM Revenue & Customs (HMRC) on October 15, 2025, added 13 more territories to the list of “Pillar Two territories” and “qualifying top-up taxes” under the UK Pillar Two rules.

HMRC in July 2025 initially added two territories (Guernsey and Spain) to the list, so with the addition of 13, there are now 15 total.

Read an October 2025 report prepared by the KPMG member firm in the UK

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