The Multinational Top-up Tax (Pillar Two Territories Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) (Amendment) Regulations SI 2025/783 allow HMRC to specify Pillar Two territories and overseas domestic top-up taxes with effect from a date before the date of the notice in which they are so specified.
This is relatively small but important change to the principal regulations on Pillar Two territories qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes (SI 2025/406) and means that HMRC are able to mirror the OECD Inclusive Framework’s practice of recognising qualified status from a date before the details are published. The regulations come into force on 24 July 2025.
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The Multinational Top-up Tax (Pillar Two Territories Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) (Amendment) Regulations SI 2025/783 allow HMRC to specify Pillar Two territories and overseas domestic top-up taxes with effect from a date before the date of the notice in which they are so specified.
This is relatively small but important change to the principal regulations on Pillar Two territories qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes (SI 2025/406) and means that HMRC are able to mirror the OECD Inclusive Framework’s practice of recognising qualified status from a date before the details are published. The regulations come into force on 24 July 2025.
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:
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