Global Daily Tax News, UK Updates List Of Territories With 'Qualifying' Pillar Two Regimes, (Oct 17, 2025)

HM Revenue and Customs has announced additions to the list of territories with compliant Pillar Two tax regimes.

The list was initially set out in The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025.

The Regulations specify which other jurisdictions the UK recognizes as having implemented Pillar Two rules that are consistent with the OECD's GloBE Rules.

Specifically, the Regulations list those territories that:

• have implemented "Qualified Income Inclusion Rules" (QIIRs) within the meaning of the OECD Model Rules;

• have implemented Qualified Domestic Minimum Top-up Taxes (QDMTTs) within the meaning of the OECD Model Rules; and

• have accredited qualifying domestic top-up taxes that are eligible for the QDMTT Safe Harbour in the meaning of the OECD Model Rules.

Among other things, the updated list notes that Japanese legislation introducing a qualifying domestic top-up tax will become effective from April 1, 2026.