Policy paper

Multinational Top-up Tax and Domestic Top-up Tax further amendments

This measure is about the amendments 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: 21 July 2025

Documents

Multinational Top-up Tax and Domestic Top-up Tax — further amendments

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Draft legislation

PDF, 549 KB, 16 pages

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Draft legislation (accessible version)

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Explanatory notes

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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. These were agreed by the UK and other members of the Organisation for Economic Co-operation and Development/G20 Inclusive Framework on Base Erosion and Profit Shifting.

This measure is comprised of amendments identified:

• from stakeholder consultation
• as necessary to make sure that UK legislation remains consistent with commentary to the GloBE rules agreed by the UK and other members of the Inclusive Framework

Published 21 July 2025