The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025
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Title and introductory text
2025 No. 406 DOMESTIC TOP-UP TAX MULTINATIONAL TOP-UP TAX The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 Made 27th March 2025 Laid before the House of Commons 31st March 2025 Coming into force 21st April 2025 The Treasury make these Regulations in exercise of the powers conferred by sections 241 and 256 of, and paragraph 2 of Schedule 16A to, the Finance (No. 2) Act 2023. The Treasury consider, in relation to territories that are specified as Pillar Two territories, that provisions implementing the Pillar Two rules relating to top-up tax under the IIR (within the meaning of those rules) have effect under the law of those territories, or will have effect on or before the date on which the specification has effect. The Treasury consider, in relation to taxes that are specified as qualifying domestic top-up taxes, that those taxes are equivalent in substance to domestic top-up tax under Part 4 of the Finance (No. 2) Act 2023.
Title and introductory text
2025 No. 406 DOMESTIC TOP-UP TAX MULTINATIONAL TOP-UP TAX The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 Made 27th March 2025 Laid before the House of Commons 31st March 2025 Coming into force 21st April 2025 The Treasury make these Regulations in exercise of the powers conferred by sections 241 and 256 of, and paragraph 2 of Schedule 16A to, the Finance (No. 2) Act 2023. The Treasury consider, in relation to territories that are specified as Pillar Two territories, that provisions implementing the Pillar Two rules relating to top-up tax under the IIR (within the meaning of those rules) have effect under the law of those territories, or will have effect on or before the date on which the specification has effect. The Treasury consider, in relation to taxes that are specified as qualifying domestic top-up taxes, that those taxes are equivalent in substance to domestic top-up tax under Part 4 of the Finance (No. 2) Act 2023.
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