The UK has updated its Pillar Two recognition lists, adding Kenya, Kuwait, Oman and the Bahamas to its QDMTT and accredited QDMTT safe harbour categories, while revising Poland's effective date and expanding the jurisdictions recognised under the OECD global minimum tax framework.
The UK has updated its list of recognised jurisdictions and taxes under the Pillar Two framework, adding four jurisdictions to its recognised Qualified Domestic Minimum Top-up Tax (QDMTT) and accredited QDMTT safe harbour lists while revising the effective date applicable to Poland.
According to an update, published on 18 May 2026, the UK has expanded the supplementary lists established under the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025.
The notice supplements the original lists of jurisdictions that have implemented Pillar Two rules and now covers 26 territories that have implemented a qualifying income inclusion rule (IIR), 27 territories with taxes recognised as QDMTTs, and 27 territories whose QDMTTs are accredited for the QDMTT safe harbour.
The latest update adds Kenya, Kuwait and Oman to both the QDMTT and accredited QDMTT safe harbour lists with an effective date of 1 January 2025. The Bahamas has also been added to both categories, effective from 1 January 2024.
HMRC additionally amended the effective date for Poland across all three Pillar Two categories. Poland’s recognition as a Pillar Two territory, as well as its QDMTT and accredited QDMTT status, has been backdated from 1 January 2025 to 1 January 2024.
Under the UK framework, jurisdictions are recognised in three categories: Pillar Two territories that have implemented Qualified Income Inclusion Rules (QIIRs), jurisdictions with Qualified Domestic Minimum Top-up Taxes (QDMTTs), and jurisdictions whose QDMTTs are accredited for the QDMTT Safe Harbour, all within the meaning of the OECD Model Rules.
The updated list of Pillar Two territories includes Gibraltar, Guernsey, Hong Kong (China), Indonesia, Isle of Man, Jersey, Malaysia, New Zealand, North Macedonia, Poland, Portugal, Qatar, Singapore, South Africa, Spain, Switzerland and Thailand, with effective dates ranging from 31 December 2023 to 1 January 2025.
For QDMTT purposes, HMRC recognises a range of domestic minimum tax regimes, including Bahrain’s Decree-Law No. (11) of 2024 Regarding the Implementation of Tax on Multinational Enterprises, Brazil’s Lei Nº 15.079, de 27 de dezembro de 2024, Singapore’s Multinational Enterprise (Minimum Tax) Act 2024, and the Bahamas’ Domestic Minimum Top-Up Tax Act, 2024. Newly added jurisdictions Kenya, Kuwait and Oman are recognised under their respective domestic legislation from 1 January 2025.
The accredited QDMTT safe harbour list mirrors the recognised QDMTT jurisdictions and legislation. Among the jurisdictions included are Japan, whose domestic minimum tax rules become accredited from 1 April 2026, and the United Arab Emirates, whose Cabinet Decision No. 142 of 2024 on the Imposition of Top-up Tax on Multinational Enterprises is recognised from 1 January 2025.
