MTT10020 - Scope: 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 are determined to be qualifying rather than groups.

Where the entity is a member of a group, the revenue threshold test (see MTT11010) is still applied to the group as a whole.

An entity will be a ‘qualifying’ entity for DTT purposes if:

  • it is located in the UK,
  • it is not an excluded entity for DTT purposes (see MTT10030), and
  • it meets the revenue threshold test as a single entity, or it is a member of a group that meets the revenue threshold test.

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

See MTT18000+ for guidance on locating entities.

See MTT01200 for an overview of DTT.