# Finance Act 2026, Paragraph 32: Qualifying undertaxed profits tax

Extent: E+W+S+N.I.

(1) For the purposes of Part 3 of F(No.2)A 2023, a tax is to be treated as a qualifying undertaxed profits tax for any accounting period that ends before the first regulations under section 257 of that Act have been made if—
(a) it is a Qualified UTPR for that accounting period for the purposes of the Pillar Two rules, or
(b) it is reasonable to conclude that it is likely to be a Qualified UTPR for that accounting period for the purposes of the Pillar Two rules.
(2) In sub-paragraph (1) “Pillar Two rules” has the same meaning as in Part 3 of F(No.2)A 2023 (see section 255 of that Act).

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Source: https://www.legislation.gov.uk/ukpga/2026/11/schedule/8/paragraph/32 (the official version)
Page: https://openlegislation.uk/finance-act-2026/schedule-8/paragraph-32
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.