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Please view the Multinational Top-up Tax and Domestic Top-up Tax collection page to see other releases of HMRC draft guidance.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

We welcome views on this partial draft guidance on Multinational Top-up Tax and Domestic Top-up Tax.

This consultation closesran atfrom
9:30am on 21 December 2023 to 11:45pm on 7 February 2024

Consultation description

HMRC has published further draft guidance on Multinational Top-up Tax and Domestic Top-up Tax in advance of implementation on 31 December 2023.

Multinational Top-up Tax is a new tax on multinational groups with annual revenue of €750m or more. A top-up tax may 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This release of draft guidance updates the previously-released pages on chargeability, scope, and administration. It also includes a new section on calculating the effective tax rate, and new pages which cover the application of Multinational Top-up Tax and Domestic Top-up Tax to particular types of entity.

HMRC invites comments from stakeholders on this draft guidance.

HMRC will publish a complete draft version of the guidance manual in due course. This will include a section on determining top-up tax amounts (covering chapters 6-8 of Part 3 of Finance (No.2) Act 2023), further guidance relating to particular types of entity and structure, and updated versions of the pages of draft guidance published here.

Documents

Draft guidance on multinational top-up tax and domestic top-up tax

ODT, 220 KB

This file is in an OpenDocument format