UK updates Pillar 2 jurisdiction list

HMRC issued an updated Notice 2 expanding the list of territories and qualifying domestic top-up taxes recognised under the Multinational Top-up Tax Regulations 2025.

The UK’s HM Revenue & Customs (HMRC) released a revised Notice 2 detailing Pillar Two top-up taxes and the applicable jurisdictions on 15 October 2025. This update expands on the original compilation of countries that have implemented Pillar 2 measures, as specified under the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes, and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025.

The UK recognises other jurisdictions which have implemented Pillar Two rules under three categories:

1. Pillar 2 territories, which have implemented “Qualified Income Inclusion Rules” (QIIRs) in the meaning of the OECD Model Rules.
2. Qualifying domestic top-up taxes — “Qualified Domestic Minimum Top-up Taxes” (QDMTTs) in the meaning of the OECD Model Rules.
3. Accredited qualifying domestic top-up taxes — QDMTTs which are eligible for the QDMTT Safe Harbour in the meaning of the OECD Model Rules.

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) (the 2025 Regulations), as amended, set out the initial lists of specified territories and qualifying taxes. This notice specifies territories and taxes which are now Pillar Two territories, qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes in addition to the initial lists. This is in accordance with the 2025 Regulations.

Pillar Two territories

Section 1.1 has the force of law under Regulation 2 of the 2025 Regulations.

This table sets out all of the following:

• the territories which are specified as Pillar Two territories
• the date from which that specification takes effect

Qualifying domestic top-up taxes

Section 1.2 has the force of law under Regulation 3 of the 2025 Regulations.

This table sets out all of the following:

• the territories in which a Qualified Domestic Minimum Top-up Tax is specified as a qualifying domestic top-up tax
• the legislation under which it is charged
• the date from which the specification as a qualifying domestic top-up tax takes effect