Consultation responses have been reviewed and are being reflected in the HMRC guidance manual where appropriate.

Please view the Multinational Top-up Tax and Domestic Top-up Tax collection page to see other releases of HMRC draft guidance.

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Original consultation

Summary

This draft guidance provides additional information on administration, chargeability and scope for multinationalMultinational top-upTop-up taxTax and domesticDomestic top-upTop-up tax.

Tax.

This consultation closesran atfrom
5pm on 15 June 2023 to 11:45pm on 12 September 2023

Consultation description

HMRC has published partial draft guidance on multinational top-up tax and domestic top-up tax, following their introduction in the Spring 2023 Finance Bill.

Multinational top-up tax is a new tax on multinational enterprise groups with annual revenue of €750m€750 million or more. A top-up tax will be charged on UK parent members when a subsidiary is located in a non-UK jurisdiction, and the group’s profits arising in that jurisdiction are taxed at a rate below the minimum effective tax rate of 15%.

Domestic top-up tax applies the rules of multinational top-up tax to the UK operations of groups and certain entities, to ensure that UK entities will be taxed at the minimum rate.

This guidance provides additional information on which groups will be in scope, and on how the taxes will be administered and charged.

HMRC invites comments from stakeholders on this draft guidance.

HMRC will publish further guidance later in due course, including updated versions of the draft chapters published here.

Documents

Multinational top-up tax and domestic top-up tax - draft guidance

PDF, 1.3 MB, 166 pages

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