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

Effective date for Poland changed from January 1, 2025, to January 1, 2024.

may 28, 2026

HMRC on May 18, 2026, updated its list of “Pillar Two territories,” “qualifying domestic top-up taxes,” and “accredited qualifying domestic top-up taxes” under the UK Pillar Two rules.

In the latest update, the effective date for Poland was changed from January 1, 2025, to January 1, 2024, in all three lists. In addition, Kenya, Kuwait, Oman, and the Bahamas were also added to the lists of qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes.

Read a May 2026 report prepared by the KPMG member firm in the UK

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