The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) (Amendment) Regulations 2025

Made: 30th June 2025

Laid before the House of Commons: 2nd July 2025

Coming into force: 24th July 2025

The Treasury make these Regulations in exercise of the powers conferred by sections 241 and 256 of, and paragraph 2 of Schedule 16A to, the Finance (No. 2) Act 2023[^f00001].

Citation and commencement

1

These Regulations may be cited as the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) (Amendment) Regulations 2025 and come into force on 24th July 2025.

Amendment of the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025

2

• (1) The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025[^f00002] are amended as follows.

• (2) After regulations 2(2), 3(2) and 4(2), insert—

(3) Specification in accordance with paragraph (2) has effect on and after the date set out in the notice (which may be a date before the publication of the notice).

Signed

Jeff Smith — Anna Turley — Two of the Lords Commissioners of His Majesty's Treasury — 30th June 2025

Explanatory note

(This note is not part of the Regulations)

Explanatory Note

These Regulations amend the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 (S.I. 2025/406) (“the 2025 Regulations”).

The 2025 Regulations specify territories as Pillar Two territories and taxes as qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes, in support of the implementation and operation of the Organisation for Economic Co-operation and Development/G20 Inclusive Framework’s Pillar Two model rules. The 2025 Regulations also provide for the Commissioners for His Majesty’s Revenue and Customs to specify further Pillar Two territories, qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes, by way of notice.

Regulation 2 of these Regulations amends regulations 2, 3, and 4 of the 2025 Regulations to enable a specification made under the 2025 Regulations to have effect on and from a date before it is made. This is authorised by sections 241(3), 256(4) of, and paragraph 2(1C) of Schedule 16A to, the Finance (No. 2) Act 2023 (c. 30).

A Tax Information and Impact Note has not been prepared for this Instrument as it contains no substantive changes to tax policy.

Footnotes

[^f00001]: 2023 c. 30; Section 241 was amended by paragraphs 8 and 51(1) of Schedule 4 to the Finance Act 2025 (c. 8). Section 256 was amended by paragraph 51(2) of Schedule 4 to the Finance Act 2025. Paragraph 2 of Schedule 16A was inserted by paragraph 41(1) of Schedule 12 to the Finance Act 2024 (c. 3) and amended by paragraph 51(3) of Schedule 5 to the Finance Act 2025.

[^f00002]: S.I. 2025/406.