Multinational Top-up Tax and Domestic Top-up Tax

MTT10010 - Scope: Overview

For MTT purposes, a group is a ‘qualifying’ group for a period if it:

• is a multinational group (see MTT10100),
• has at least one member located in the UK, and
• meets the revenue threshold test (see MTT11000).

References to a ‘group’ in this guidance manual will generally mean a qualifying multinational group.

Certain types of entity are excluded from scope, even when they are in a qualifying group (see MTT10200+).

Domestic Top-up Tax

Domestic Top-up Tax (DTT) can apply to wholly domestic groups and single entities, in addition to the UK operations of multinational groups. For DTT purposes, it is entities that will be qualifying rather than groups.

Consequently, for DTT purposes, references in HMRC guidance to a ‘qualifying group’ will refer to any entity or group that includes members that qualify for DTT, and references to a ‘multinational group’ will also refer to wholly domestic groups and single entities unless otherwise specified.

See MTT10020 for guidance on scope for DTT.

See MTT01200 for an overview of DTT.

Safe harbours

See MTT15000+ for guidance on safe harbours that limit the application of MTT and DTT where the conditions are met.

See MTT62900+ for guidance on the transitional safe harbour for the Undertaxed Profits Rule (UTPR).

Determining ownership and location of entities

See MTT17000+ for guidance on determining ownership of entities, and MTT18000+ for guidance on locating entities. These provisions are significant for questions of scope but also have significance in calculating the effective tax rate of territories, the top-up amounts of entities, and the charging provisions.