Multinational Top-up Tax and Domestic Top-up Tax

MTT50200 - Administration: Administration of Domestic Top-up Tax

Domestic Top-up Tax (DTT) is a tax that is calculated and administered in a similar way to Multinational Top-up Tax (MTT), with some exceptions. The guidance in this manual is generally applicable for both DTT and MTT, and references to MTT will also be references to DTT unless specified.

This page provides guidance on the differences in administration between DTT and MTT. See MTT01200 for a wider overview of DTT.

This is set out in paragraphs 3-5,  Schedule 18 to Finance (No.2) Act 2023.

Differences in scope

MTT applies exclusively to multinational groups.

DTT can apply to entities in wholly domestic groups in addition to multinational groups. Consequently, any references in the guidance to multinational groups should be considered to include wholly domestic groups in the context of DTT.

MTT can only apply to groups, but DTT can apply to individual entities. In such a case, references in the guidance to a group, members of a group, or the filing member of a group, should be taken as references to the individual entity.

Filing member

The filing member for DTT will be the same as the MTT filing member. This is the case regardless of whether the filing member is the default filing member or a nominated alternative filing member.

The filing member will change for both taxes when an alternative filing member is nominated or when such a nomination is revoked or ceases to be valid (see MTT51200).

Filing member – individual entity in scope of DTT

It is possible for DTT to apply to an individual entity. In this case, the concept of identifying or nominating an alternative filing member will not be relevant as the entity will necessarily be responsible for all DTT obligations.

Registration

The registration process is the same for both DTT and MTT. Where a group is obliged to register for both, this can be done by a single registration.

The registration service is available online.

Registration – trigger day

The ‘trigger day’ is the first day of the first accounting period in which a member of the group that is located in the UK is a qualifying entity.

Penalties

The MTT penalty regime is replicated for DTT purposes. See MTT50210 for further guidance.