Multinational Top-up Tax and Domestic Top-up Tax

MTT65010 - Charging mechanisms: Domestic Top-up Tax charge: Overview

The charging provision for DTT is different to the IIR charge under MTT. This is because the concepts of responsible members and the inclusion ratio do not exist for DTT. Instead, qualifying members are generally chargeable persons for DTT.

The calculation of a member’s top-up amount is also different for DTT. In DTT, top-up amounts are allocated only to those members with adjusted profits, in accordance with their effective tax rates and adjusted profits. Amounts are thereby allocated proportionately to those members which generated the top-up amount for the territory.

These top-up amounts are not further attributed to another member under the DTT charging mechanism, except where the member is neither a body corporate nor a partnership.

A group may elect for a single member to be liable for all DTT top-up amounts.

See MTT65020 for guidance on chargeable persons for DTT, and how the top-up amount of a member which is neither a body corporate nor a partnership will be brought into charge.

See MTT65030 for guidance on the amount to be charged to each qualifying member.

See MTT65040 for guidance on the election to make one member liable.

For guidance on calculating the top-up amount of an entity under DTT, see MTT31100.