MTT09970 - Reference materials: List of qualifying taxes
Source: gov.uk (2025-10-17)


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 (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/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 (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/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:

Territory

Date

Australia

1 January 2024

Austria

31 December 2023

Belgium

31 December 2023

Bulgaria

31 December 2023

Canada

31 December 2023

Croatia

31 December 2023

Czech Republic

31 December 2023

Denmark

31 December 2023

Finland

31 December 2023

France

31 December 2023

Germany

31 December 2023

Gibraltar

1 January 2025

Greece

31 December 2023

Guernsey

1 January 2025

Hungary

31 December 2023

Indonesia

1 January 2025

Ireland

31 December 2023

Isle of Man

1 January 2025

Italy

31 December 2023

Japan

1 April 2024

Jersey

1 January 2025

Liechtenstein

1 January 2024

Luxembourg

31 December 2023

Malaysia

1 January 2025

Netherlands

31 December 2023

New Zealand

1 January 2025

North Macedonia

1 January 2024

Norway

1 January 2024

Poland

1 January 2025*

Portugal

1 January 2024

Republic of Korea

1 January 2024

Romania

31 December 2023

Singapore

1 January 2025

Slovenia

31 December 2023

South Africa

1 January 2024

Spain

31 December 2023

Sweden

31 December 2023

Switzerland

1 January 2025

Thailand

1 January 2025

Turkey

1 January 2024

United Kingdom

31 December 2023

Vietnam

1 January 2024

*To recognise Poland as a Pillar Two territory with an effective date of 1 January 2024 for those groups that have elected into the Polish rules will require new legislation.

List of qualifying domestic top-up taxes

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

Territory

Date

Australia

1 January 2024

Austria

31 December 2023

Barbados

1 January 2024

Belgium

31 December 2023

Brazil

1 January 2025

Bulgaria

31 December 2023

Canada

31 December 2023

Croatia

31 December 2023

Czechia

31 December 2023

Denmark

31 December 2023

Finland

31 December 2023

France

31 December 2023

Germany

31 December 2023

Gibraltar

1 January 2024

Greece

31 December 2023

Guernsey

1 January 2025

Hungary

31 December 2023

Indonesia

1 January 2025

Ireland

31 December 2023

Isle of Man

1 January 2025

Italy

31 December 2023

Japan

1 April 2026

Liechtenstein

1 January 2024

Luxembourg

31 December 2023

Malaysia

1 January 2025

Netherlands

31 December 2023

North Macedonia

1 January 2024

Norway

1 January 2024

Poland

1 January 2025*

Portugal

1 January 2024

Romania

31 December 2023

Singapore

1 January 2025

Slovakia

31 December 2023

Slovenia

31 December 2023

South Africa

1 January 2024

Spain

31 December 2023

Sweden

31 December 2023

Switzerland

1 January 2024

Thailand

1 January 2025

Turkey

1 January 2024

United Arab Emirates

1 January 2025

United Kingdom

31 December 2023

Vietnam

1 January 2024

*To recognise Poland as a territory having a with an effective date of 1 January 2024 for those groups that have elected into the Polish rules will require new legislation.

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.

Territory

Date

Australia

1 January 2024

Austria

31 December 2023

Barbados

1 January 2024

Belgium

31 December 2023

Brazil

1 January 2025

Bulgaria

31 December 2023

Canada

31 December 2023

Croatia

31 December 2023

Czechia

31 December 2023

Denmark

31 December 2023

Finland

31 December 2023

France

31 December 2023

Germany

31 December 2023

Gibraltar

1 January 2024

Greece

31 December 2023

Guernsey

1 January 2025

Hungary

31 December 2023

Indonesia

1 January 2025

Ireland

31 December 2023

Isle of Man

1 January 2025

Italy

31 December 2023

Japan

1 April 2026

Liechtenstein

1 January 2024

Luxembourg

31 December 2023

Malaysia

1 January 2025

Netherlands

31 December 2023

North Macedonia

1 January 2024

Norway

1 January 2024

Poland

1 January 2025*

Portugal

1 January 2024

Romania

31 December 2023

Singapore

1 January 2025

Slovakia

31 December 2023

Slovenia

31 December 2023

South Africa

1 January 2024

Spain

31 December 2023

Sweden

31 December 2023

Switzerland

1 January 2024

Thailand

1 January 2025

Turkey

1 January 2024

United Arab Emirates

1 January 2025

United Kingdom

31 December 2023

Vietnam

1 January 2024

*To recognise Poland as a territory having an accredited QDMTT with an effective date of 1 January 2024 for those groups that have elected into the Polish rules will require new legislation.