United Kingdom Tax Agency Issues Notice Updating Territory Lists for Pillar 2 Minimum Taxation Rules

June 1, 2026, 5:00 AM UTC

The United Kingdom HM Revenue and Customs May 18 issued Notice No. 2, on the updated categories for territories that have implemented OECD Pillar Two rules, for the multinational top-up tax (MTT) and domestic top-up tax (DTT). The notice includes updated lists of territories, with categories for: 1) territories specified as Pillar Two territories, which have implemented qualified income inclusion rules (QIIRs); 2) territories in which the qualified domestic minimum top-up tax (QDMTT) is specified as a qualifying domestic top-up tax (QDTT); and 3) territories where the QDMTT is specified as an accredited QDTT. The notice also includes effective dates ...

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