On 24 July 2025, His Majesty’s Revenue & Customs (HMRC) issued Notice 2 — Pillar Two top-up taxes relevant territories and taxes under the Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 (SI 2025/406) (previous coverage). The notice supplements the original lists by adding Spain and Guernsey as: (i) Pillar Two territories (jurisdictions that have implemented a qualified income-inclusion r…