Policy paper

Introduction of the Side-by-Side package and amendments to Multinational Top-up Tax and Domestic Top-up Tax

This measure is about the UK implementation of the Side-by-Side package and amendments being made to Multinational Top-up Tax and Domestic Top-up Tax.

• From: HM Revenue & Customs
• Published: 13 July 2026

Documents

Pillar 2 — Side-by-Side package and further amendments to Multinational Top-up Tax and Domestic Top-up Tax

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Draft legislation

PDF, 340 KB, 30 pages

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Explanatory note

ODT, 30.7 KB

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Details

This measure implements the Side-by-Side package into UK legislation in line with the guidance published by the Organisation for Economic Co-operation and Development (OECD) in January 2026.

It also makes amendments to Multinational Top-up Tax and Domestic Top-up Tax to make sure UK legislation remains consistent with the commentary and guidance developed by the UK and other members of the Inclusive Framework.

Published 13 July 2026