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Domestic Top-up Tax and Multinational Top-up Tax: detailed information

Policy papers, consultations, guidance and statutory guidance about Pillar 2 top-up taxes, including how to register to report these taxes to HMRC.

The Pillar 2 agreement

In October 2021, more than 135 countries, including the UK, reached an agreement known as ‘Pillar 2’. This agreement ensures that the largest corporate groups will be subject to a minimum rate of tax, by enacting a global minimum corporate tax rate of 15%.

As part of that agreement, the government has introduced 2 new taxes in the UK:

  • Domestic Top-up Tax
  • Multinational Top-up Tax

These taxes apply to accounting periods beginning on or after 31 December 2023.

HMRC are currently delivering this service on a phased approach. You can now register for Pillar 2 top-up taxes. We’ll release the tools that you need to submit your returns before the due date for reporting.

Contact us

If you have a technical question about Pillar 2 top-up taxes, you can email us at pillar2mailbox@hmrc.gov.uk.

Guidance

This guidance will help agents and other customers who are likely to be affected by the Pillar 2 top-up taxes.

Webinars

Our webinars are aimed at businesses that must comply with the new Pillar 2 rules. They will also support external agents or firms that provide advice on Pillar 2 to those businesses.

The first took place on 30 April 2025.

The second took place on 10 July 2025 and covered:

  • the purpose of OECD Pillar 2 Transitional Safe Harbour
  • the Transitional Safe Harbour requirements 
  • qualified country-by-country reports
  • adjustments to figures used for the purposes of the Safe Harbour
  • tests to qualify for the Transitional Safe Harbour
  • Transitional Safe Harbour election and compliance requirements

Webinars are recorded and available on the following guidance page.

Statutory guidance

These notices contain tertiary legislation that applies for the purposes of Multinational Top-up Tax and Domestic Top-up Tax. Tertiary legislation carries ‘force of law’. This means it has the same legal status as primary and secondary legislation. HMRC has an obligation to publish this information in accordance with the law.

Public consultations

Consultations on the implementation of Pillar 2 and HMRC’s draft guidance, including summaries of public responses.

Policy papers

Policy papers that outline the detail and intentions behind Domestic Top-up Tax and Multinational Top-up Tax.

Updates to this page

Published 11 July 2024
Last updated 8 July 2025 show all updates
  1. Published details of webinar taking place on 10 July 2025.

  2. Information on paying Pillar 2 top-up taxes has been added.

  3. Added new section about HMRC webinars.

  4. 'Multinational Top-up Tax and Domestic Top-up Tax supplementary draft guidance' added to consultations section.

  5. Added 'Multinational Top-up Tax and Domestic Top-up Tax - further draft guidance' to public consultations section and added new section 'Report Pillar 2 top-up taxes'.

  6. First published.