Section 257 Qualifying undertaxed profits tax

United Kingdom

(1)

For the purposes of this Part a tax is a “qualifying undertaxed profits tax” if it is F1—

(a)

multinational top-up tax (see, in particular, Chapter 9A), or

(b)

specified in regulations made by the Treasury.

F2(1A)

Regulations under subsection (1)(b) may provide for the specification of a tax to be made by notice published by the Commissioners for His Majesty’s Revenue and Customs in accordance with the regulations.

(2)

F3A person may only specify a tax by virtue of this section if the person considers that the tax is an appropriate means of implementing the UTPR (within the meaning of the Pillar Two rules).

(3)

Regulations under this section may provide that the specification of a tax is to have effect from a time before the regulations are made (but may not provide that the specification of a tax previously specified ceases to have effect before the regulations are made).

Annotations

Textual amendments

F1: Words in s. 257(1) inserted (in relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 7(2), 10
F2: S. 257(1A) inserted (in relation to accounting periods beginning on or after 31.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 30(2), 53(1)
F3: Words in s. 257(2) substituted (in relation to accounting periods beginning on or after 31.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 30(3), 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)