Multinational Top-up Tax and Domestic Top-up Tax

MTT65040 - Charging mechanisms: Domestic Top-up Tax charge: Election to make one member liable

If multiple members of a group are chargeable to Domestic Top-up Tax (DTT) in an accounting period, the filing member may elect that only one member of the group (the 'elected member') is liable to pay the DTT chargeable on any member of the group for that period.

Where an election is made, the elected member will become liable for those amounts of DTT. None of the other members of the group will be liable.

The elected member must consent to such an election, in accordance with section 271(3) Finance (No.2) Act 2023, in order for the election to take effect.

This election is an annual election. See MTT52200 for guidance on making an annual election.

Treatment of amounts allocated under the election

When a member has been made liable as a result of the election, the amount of tax is to be treated in the same way as an amount for which the member would ordinarily be liable.

For example, the payment date will be the same for the elected member as it would have been for the other group member, and a group payment notice may be issued in respect of the liability.

See MTT54000+ for guidance on payments of MTT and DTT.