HMRC confirms Spain and Guernsey as recognised Pillar Two jurisdictions in Notice 2 issued on 24 July 2025.
The UK’s tax, payments and customs authority, His Majesty’s Revenue & Customs (HMRC) issued Notice 2 — Pillar Two top-up taxes relevant territories and taxes on 24 July 2025.
The notice was issued under The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 (SI 2025/406). It confirms the inclusion of Spain and Guernsey as recognised jurisdictions for Pillar Two purposes.
The notice updates the list of territories that have implemented measures consistent with the OECD’s Global Anti-Base Erosion (GloBE) Rules. Specifically, Spain and Guernsey are now recognised as:
- Pillar Two territories, which have implemented “Qualified Income Inclusion Rules” (QIIRs) in the meaning of the OECD Model Rules.
- Qualifying domestic top-up taxes — “Qualified Domestic Minimum Top-up Taxes” (QDMTTs) in the meaning of the OECD Model Rules.
- Accredited qualifying domestic top-up taxes — QDMTTs, which are eligible for the QDMTT Safe Harbour in the meaning of the OECD Model Rules.
Spain’s recognition is retroactive to 31 December 2023, the effective date of Spain’s Law 7/2024 introducing a 15% minimum tax. Guernsey’s recognition takes effect from 1 January 2025, aligning with its 2024 Pillar Two regulations.
These designations align the UK’s implementation of Pillar Two with the OECD Model Rules, enabling consistent application of top-up taxes for multinational enterprises operating in the listed jurisdictions.
