Multinational Top-up Tax and Domestic Top-up Tax

MTT33010 - Calculating top-up amounts: Additional top-up amounts: Overview

An additional top-up amount can arise in two different scenarios:

• where there is a negative covered tax balance that exceeds 15% of a loss in the adjusted profits (see MTT33100), or
• where a recalculation of a prior period results in an increase to the top-up tax for that period (see MTT33200).

An additional top-up amount will first be calculated as a collective additional amount for the members in the territory.

Amounts of Qualifying Domestic Minimum Top-up Tax may be credited against the collective additional amount.

The collective additional amount is then allocated between the members. The method of allocation differs depending on which circumstance gave rise to the collective additional amount.

The additional top-up amount of each member is then brought into charge in broadly the same manner as an ordinary top-up amount of the member (see MTT31000), with certain alterations.

See MTT61020+ and MTT65020+ for guidance on chargeability for MTT and DTT respectively.

Election to carry forward and reduce collective additional amount where covered taxes less than expected

Where the collective additional amount arose where covered taxes were less than expected, an election can be made to carry forward the amount to a year where there is an adjusted profit for the territory. See MTT33120 for further guidance.