Multinational Top-up Tax and Domestic Top-up Tax

MTT41630 - Particular entities and adjustments: Joint venture groups: Chargeability

Where an MTT top-up amount is calculated for a joint venture group, it will be charged to a responsible member under the ordinary rules, as though the joint venture were a member of the consolidated group.

See MTT61010 for guidance on chargeability for MTT purposes.

Chargeability of joint venture group members under primary charging mechanism

A member of a joint venture group cannot be an intermediate parent member or a partially owned parent member of that group. By definition, a member of a joint venture group cannot be the ultimate parent of a group.

Therefore, a member of a joint venture group cannot be a responsible member and will not itself receive an MTT charge.

Chargeability of joint venture group members under the Undertaxed Profits Rule

Where joint venture group members are determined to have an untaxed amount under the UTPR, those amounts will be charged to other members of the consolidated group.

See MTT62120 for guidance on the treatment of joint venture groups under the UTPR.

Domestic Top-up Tax

The guidance on this page does not apply for DTT purposes. Chargeability is different under MTT and DTT. See MTT41640 for guidance on chargeability of joint venture groups for DTT purposes.