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Multinational Top-up Tax and Domestic Top-up Tax

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Updates: Multinational Top-up Tax and Domestic Top-up Tax

2026

11 August 2026 published amendments

Miscellaneous pages: Accounting terms: Consolidated financial statements

Clarification of the language relating to application of the deemed consolidation test in section 249(1)(d) and section 249(2).

Scope: Excluded entities: Overview

The language under "Entities excluded when they are the ultimate parent" and the following example were made more precise, to prevent misinterpretation of the effect of section 249(2).

10 August 2026 published amendments

Scope: Determining ownership of entities: Ownership interests and controlling interests

Updated for change in FA26 in relation to a main entity not having an ownership interest in a permanent establishment.

26 June 2026 published amendments

23 April 2026 published amendments

Calculating the effective tax rate: Covered tax balance: Covered taxes

Added detail of the FA26 changes to the DTT treatment of group relief payments

22 April 2026 published amendments

Administration: The information return: Making elections

Added details of the transitional extension to the deadline for elections introduced by Finance Act 2026

2025

5 August 2025 published amendments