Multinational Top-up Tax and Domestic Top-up Tax

MTT54110 - Administration: Payments and interest: Allocating payments of Multinational Top-up Tax and Domestic Top-up Tax

Please check this page for details on how to make a payment.

If the group’s DTT and MTT liabilities are not completely settled by their payment due date, there will be a need to determine which group members still have an outstanding liability. In this situation, HMRC will allocate payments following specific ordering rules. These rules would also be applied if a partial payment is received after the payment due date. These ordering rules are set out in more detail below.

If the group wishes for their payments to be allocated on an alternative basis, the filing member should contact HMRC at pillar2mailbox@hmrc.gov.uk and provide the following information:

• the Pillar 2 reference number
• the names and Tax Identification Numbers of the entities to which the payments should be allocated
• the amount that should be allocated to each entity

Payment allocation ordering rules

In the absence of specific instructions relating to a payment, HMRC will apply the following approach to allocating payments against unpaid liabilities.

1. Oldest interest-bearing liability. If there are multiple unpaid liabilities with the same due date, payments will be allocated in the following priority order:

i.   DTT liabilities

ii.  MTT – UTPR liabilities

iii. MTT – IIR liabilities

2. Any Overpayment Relief Charge amounts
3. The oldest non-interest-bearing liability. This will typically be DTT or MTT related penalties. If there is more than one such liability with the same due date, the payments will be allocated in the following order:

i.  DTT related penalties

ii. MTT related penalties

4. Late payment interest in respect of any of the above listed charges. Where there is late payment interest in respect of multiple liabilities, payments would be allocated using the same order of priority as set out in (1) - (3) above.

If there are multiple liabilities that would fall within one of the categories listed above, the payment will be allocated to the smallest one first. If there are multiple charges of the same amount, the payment will be allocated on an alphabetical basis based on the name of the entity the liability is in respect of.

In order to allocate payments, HMRC will rely on information provided by the filing member and information held by HMRC in connection with its statutory functions.

This process may involve HMRC confirming, referring to, or otherwise using information previously provided by the filing member to HMRC about other entities included in the UK self-assessment return, (including but not limited to entity details, taxpayer identification numbers and liabilities), where this is necessary to process payment allocation requests.

Where the filing member acts on behalf of one or more entities, it must be authorised to do so. HMRC will treat communications with the filing member as made on behalf of those entities and may use or confirm information relating to them accordingly.

By submitting a request to allocate payments, the filing member confirms that it has the necessary authority from the relevant entities for HMRC to process and, where necessary, to provide such information to it for these purposes.

HMRC will only use or share information to the extent necessary for the exercise of its statutory functions.