Multinational Top-up Tax and Domestic Top-up Tax

MTT41640 - Particular entities and adjustments: Joint venture groups: Chargeability – Domestic Top-up Tax

In Domestic Top-up Tax, an entity will be chargeable if it is a qualifying entity (see MTT10020).

A joint venture group member will be a qualifying entity if:

• it is located in the UK,
• it is not an excluded entity for DTT purposes (see MTT10030), and
• it is owned by:
• a group that is subject to MTT or a foreign equivalent, or
• a single entity that is in scope of DTT.

Application of chargeability rules to joint venture groups

The general rules for determining the amount to be charged to a member at MTT65030 will apply to joint venture groups.

See MTT31100 for guidance on calculating the top-up amount of an entity for DTT purposes, and MTT61020 for guidance on chargeable persons.

Reporting liabilities

Where a joint venture group is owned by more than one consolidated group or entity that is in scope of DTT, the filing members for each consolidated group (or the single entity) will record 100% of the DTT allocated to members of the joint venture group within their respective returns.

Where a payment is made against the liability of a member of a joint venture group, this will reduce the liability for that member in relation to both groups.

Amendment in Finance Act 2025

Section 227 was amended by FA25. This guidance page reflects the current version of the legislation. Consult FA25 for legislation applicable to prior periods if the retrospection election does not apply (see MTT09490).