Multinational Top-up Tax and Domestic Top-up Tax

MTT54320 - Administration: Payments and interest: Excessive amount repaid by HMRC

If an amount of MTT has been repaid, and the amount repaid exceeds the amount that HMRC were liable to repay at that time, HMRC may recover any excess amount that should not have been repaid.

HMRC will assess the amount that should not have been repaid and notify the amount to the person to whom the repayment was made.

If the total amount assessed is determined to be less than the amount that should have been assessed, HMRC can make a supplementary assessment of the tax due within the time window. HMRC will make a separate notification of this amount to the person to whom the repayment was made. That person will then be liable to MTT for that amount.

HMRC may reduce or withdraw the assessment if appropriate. The person’s liability would then be reduced accordingly.

This is set out in paragraph 54, Schedule 14 to Finance (No.2) Act 2023.

The time window

The assessment must be made within 4 years of the end of the accounting period in which HMRC become aware of evidence of facts sufficient to support the assessment.