MTT09970 | Reference materials: List of qualifying taxes

There are three types of taxes which may be determined to be qualifying Pillar Two taxes:

• Income Inclusion Rules (equivalent to MTT collected under the main charging mechanism)

• UTPRs (equivalent to MTT collected under the Undertaxed Profits Rule)

• Domestic Top-up Taxes (when qualifying, Qualified Domestic Minimum Top-up Taxes or ‘QDMTTs’)

QDMTTs may also be accredited. If a QDMTT is accredited, groups may make a QDMTT Safe Harbour election for those territories (see MTT15100+).

The UK’s Pillar Two taxes are specified in primary legislation as qualifying and accredited from their implementation dates. This is set out in section 241, section 256, section 257, and Schedule 16A, paragraph 2 of Finance (No.2) Act 2023.

A territory which has been specified as having a Qualifying Income Inclusion Rule is called a ‘Pillar Two territory’.

Legislation

Qualifying Pillar Two taxes have been specified in secondary legislation under regulations (‘the Regulations’), titled ‘Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 (SI 2025/406)’.

Under the Regulations, HMRC will specify by Notice additional territories and taxes which are Pillar Two territories, QDMTTs and accredited QDMTTs.

See MTT09980 for a record of the secondary legislation and notices.

List of Pillar Two territories

The following are Pillar Two territories, as of these effective dates:

*Poland will be recognised as a Pillar Two territory with effect from 1 January 2024. However, as the Polish IIR is applied by election for 2024, the status as a Pillar Two territory will only have effect for a group if they have made the election.

List of qualifying domestic top-up taxes

The following territories have QDMTTs, as of these effective dates:

* Poland will be recognised as having a QDMTT with effect from 1 January 2024. However, as the Polish QDMTT is applied by election for 2024, the status of the QDMTT will only have effect for a group if they have made the election.

List of accredited qualifying domestic top-up taxes

The following territories have QDMTTs that are accredited, as of these effective dates.

At present, all QDMTTs are accredited.

* Poland will be recognised as having an accredited QDMTT with effect from 1 January 2024. However, as the Polish QDMTT is applied by election for 2024, the status of the accredited QDMTT will only have effect for a group if they have made the election.