Draft guidance on Multinational Top-up Tax and Domestic Top-up Tax
Detail of outcome
Consultation responses have been reviewed and are being reflected in the HMRC guidance manual where appropriate.
Please view the Multinational Top-up Tax and Domestic Top-up Tax collection page to see other releases of HMRC draft guidance.
Original consultation
Consultation description
HMRC has published further draft guidance on Multinational Top-up Tax and Domestic Top-up Tax in advance of implementation on 31 December 2023.
Multinational Top-up Tax is a new tax on multinational groups with annual revenue of €750m or more. A top-up tax may be charged on UK parent members when a subsidiary is located in a non-UK jurisdiction, and the group’s profits arising in that jurisdiction are taxed at a rate below the minimum effective tax rate of 15%.
Domestic Top-up Tax applies the rules of Multinational Top-up Tax to the UK operations of groups and certain entities, to ensure that UK entities will be taxed at the minimum rate.
This release of draft guidance updates the previously-released pages on chargeability, scope, and administration. It also includes a new section on calculating the effective tax rate, and new pages which cover the application of Multinational Top-up Tax and Domestic Top-up Tax to particular types of entity.
HMRC invites comments from stakeholders on this draft guidance.
HMRC will publish a complete draft version of the guidance manual in due course. This will include a section on determining top-up tax amounts (covering chapters 6-8 of Part 3 of Finance (No.2) Act 2023), further guidance relating to particular types of entity and structure, and updated versions of the pages of draft guidance published here.
Documents
Updates to this page
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Added the outcome of the consultation.
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First published.