Section 241 Pillar Two territories

United Kingdom

(1)

In this Part “Pillar Two territory” means the United Kingdom and every other territory specified as such in F1, or in accordance with, regulations made by the Treasury.

F2(1A)

Regulations may provide for the specification of a territory to be made by notice published by the Commissioners for His Majesty’s Revenue and Customs in accordance with the regulations.

(2)

Regulations F3, or a notice, may only specify a territory as a Pillar Two territory if the F4appropriate authority considers that provisions F5which implement the provisions of the Pillar Two rules relating to top-up tax under the IIR (within the meaning of those rules)—

(a)

have effect under the law of that territory, or

(b)

will have effect under the law of that territory on or before the specification has effect.

F6(2A)

The “appropriate authority” means—

(a)

in relation to the specification of a territory in regulations, the Treasury, or

(b)

in relation to the specification of a territory made by notice, the Commissioners for His Majesty’s Revenue and Customs.

(3)

Regulations under this section may provide F7for the specification of a territory F8... to have effect from a time before F9the territory was specified (but may not provide F10for the specification of a territory to cease to have effect in relation to accounting periods commencing before the regulations are made).

F11(4)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Annotations

Textual amendments

F1: Words in s. 241(1) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(a), 72(1)(d)
F2: S. 241(1A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(b), 72(1)(d)
F3: Words in s. 241(2) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(c)(i), 72(1)(d)
F4: Words in s. 241(2) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(c)(ii), 72(1)(d)
F5: Words in s. 241(2) substituted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 8, 10
F6: S. 241(2A) inserted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(d), 72(1)(d)
F7: Word in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(i), 72(1)(d)
F8: Word in s. 241(3) omitted (in relation to accounting periods commencing on or after 31.12.2023) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(ii), 72(1)(d)
F9: Words in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(iii), 72(1)(d)
F10: Words in s. 241(3) substituted (in relation to accounting periods commencing on or after 31.12.2023) by Finance Act 2025 (c. 8), Sch. 4 paras. 51(1)(e)(iv), 72(1)(d)
F11: S. 241(4) omitted (in relation to accounting periods beginning on or after 31.12.2025) by virtue of Finance Act 2026 (c. 11), Sch. 8 paras. 28, 53(1)

Notes on Part 3

Modifications

C1: Pt. 3 modified (2.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 32, 53(3)