Multinational Top-up Tax and Domestic Top-up Tax

MTT51100 - Administration: Filing member: Identifying the filing member

By default, the filing member will be the ultimate parent of the group, even when it is located outside of the UK.

A company that is a member of the group may be nominated as an alternative filing member (see MTT51200).

This is set out in paragraphs 2(1), (12) and (13), schedule 14 to Finance (No.2) Act 2023.

See MTT10110 for guidance on identifying the ultimate parent of the group.

Ultimate parent is not a company

Where a trust or a partnership is the ultimate parent, its obligations as the filing member may be discharged by certain partners or trustees (see MTT51300).

Multiparent groups

Where a multiparent group has not nominated a specific filing member, every ultimate parent in the multiparent group will be the filing member by default. Each of these entities will bear the obligations of the filing member (see MTT51300).

In all other cases, there will only be one filing member at any time.