Policy paper

Further amendments to Multinational Top-up Tax and Domestic Top-up Tax

This tax information and impact note is about updates being made to the Multinational Top-up Tax and Domestic Top-up Tax, which were brought in as part of the UK's implementation of Pillar 2.

• From: HM Revenue & Customs
• Published: 26 November 2025

Documents

Pillar 2: Further amendments to Multinational Top-up Tax and Domestic Top-up Tax

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Draft legislation (accessible version)

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Draft legislation

PDF, 230 KB, 6 pages

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Details

Multinational Top-up Tax and Domestic Top-up Tax are the UK’s adoption of the Pillar 2 Global Anti-Base Erosion (GloBE) rules, agreed by the UK and other members of the Organisation for Economic Co-operation and Development (OECD) and G20 Inclusive Framework on base erosion and profit shifting.

This measure makes amendments identified from stakeholder consultation or otherwise necessary to ensure the UK’s legislation remains consistent with the commentary and administrative guidance to GloBE rules developed by the UK and other members of the Inclusive Framework.

Published 26 November 2025