Jurisdictions › United Kingdom
Enacted

United Kingdom Pillar Two

Europe

Effective
Jan 2024
IIR local name
Multinational Top-up Tax (MTT)
UTPR local name
Undertaxed Profits Tax (UTP)
QDMTT local name
Domestic Top-up Tax (DTT)
IIR
Multinational Top-up Tax (MTT)
Enacted
UTPR
Undertaxed Profits Tax (UTP)
Enacted
QDMTT
Domestic Top-up Tax (DTT)
Enacted
In development — This profile is provided for reference only and may contain inaccuracies. Always verify against official legislation and current OECD guidance.
Key implementation point

UK rebranded all three rules — MTT, DTT, UTP — departing from OECD model rule labels.

Implementation detail
  • 01 UK uses distinct nomenclature: MTT (IIR), DTT (QDMTT) and UTP (UTPR) — not the OECD standard labels.
  • 02 DTT applies to UK constituent entities of in-scope MNE groups, topping up to 15% on UK profits.
  • 03 UTP (UTPR) deferred by one year: effective for accounting periods beginning on or after 31 Dec 2024.
  • 04 Transitional safe harbour: UK CbCR-based simplified ETR test available for qualifying periods.
  • 05 HMRC published detailed guidance including a Pillar Two manual updated through 2025.
Enacted legislation Finance (No.2) Act 2023
Track United Kingdom rules against your live MNE

In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.

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