MTT61020 - Charging mechanisms: The charge: Chargeable persons

A person is chargeable to MTT for a period if:

  • they are a member of a qualifying multinational group for that period,
  • they are a body corporate or a partnership, and
  • they are located in the UK.

In some cases, persons may be chargeable to MTT in respect of a member.

Under the primary charging mechanism, only responsible members will be charged amounts of MTT (although other persons may be charged amounts in respect of a responsible member). Under the Undertaxed Profits Rule (UTPR), any member of the group may be charged an amount of MTT.

This is set out in section 122 of Finance (No.2) Act 2023.

See MTT61030 for guidance on identifying the responsible members, and see MTT62110 for guidance on chargeability under UTPR.

Domestic Top-up Tax

Guidance on these pages is not applicable for Domestic Top-up Tax. For guidance on DTT chargeability, see MTT65020.

Member is neither a body corporate nor a partnership

Another person may be chargeable to tax in respect of a member if the member is:

  • neither a body corporate nor a partnership, and
  • located in the UK.

A person will be chargeable in respect of such a member if the profits of that member would be the profits of that person for the purpose of income tax or corporation tax, assuming that:

  • the responsible member had profits that were chargeable to income tax or corporation tax, and
  • that person was resident in the UK for the purposes of that tax.

Where more than one person is chargeable in respect of the same member, these persons are jointly and severally liable.

Group payment notice

If a chargeable person fails to pay their MTT liability, HMRC may issue a notice to another to make it liable for the amount. See MTT54200+ for more information on group payment notices.