Multinational Top-up Tax and Domestic Top-up Tax: Supplementary draft guidance
- From:
- HM Revenue & Customs
- Published
- 28 January 2025
- Last updated
- 9 June 2025 — See all updates
Detail of outcome
Consultation responses have been reviewed and have been, or will be, 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Please view the Multinational Top-up Tax and Domestic Top-up Tax collection page to see other releases of HMRC draft guidance.
Original consultation
Summary
We welcome views on this supplementary release of draft HMRC guidance for Multinational Top-up Tax and Domestic Top-up Tax.
This consultation closesran atfrom
to
Consultation description
HMRC has published a document of supplementary draft guidance on Multinational Top-up Tax and Domestic Top-up Tax.
This release of draft guidance contains sections on flow-through entities, joint ventures, the insurance sector, additional top-up amounts, and other topics. It also contains draft guidance on the undertaxed profits rule (UTPR) and certain other provisions that have been amended or introduced in the current Finance Bill.
HMRC invites comments from stakeholders on this draft guidance, as well as any previously released draft guidance. This will be the final release of draft guidance before publication of the manual.
You can access previous releases of draft guidance on GOV.UK.
Documents
Multinational Top-up Tax and Domestic Top-up Tax – Supplementary draft guidance
ODT, 343 KB
This file is in an OpenDocument format
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Updates to this page
Published 28 January 2025
Last updated 9 June 2025
href="#full-history">+ show all updates
-
Published consultation outcome.
-
First published.
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Consultation responses have been reviewed and have been, or will be, 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Please view the Multinational Top-up Tax and Domestic Top-up Tax collection page to see other releases of HMRC draft guidance.
Original consultation
Summary
We welcome views on this supplementary release of draft HMRC guidance for Multinational Top-up Tax and Domestic Top-up Tax.
This consultation closesran atfrom
to
Consultation description
HMRC has published a document of supplementary draft guidance on Multinational Top-up Tax and Domestic Top-up Tax.
This release of draft guidance contains sections on flow-through entities, joint ventures, the insurance sector, additional top-up amounts, and other topics. It also contains draft guidance on the undertaxed profits rule (UTPR) and certain other provisions that have been amended or introduced in the current Finance Bill.
HMRC invites comments from stakeholders on this draft guidance, as well as any previously released draft guidance. This will be the final release of draft guidance before publication of the manual.
You can access previous releases of draft guidance on GOV.UK.
Documents
Multinational Top-up Tax and Domestic Top-up Tax – Supplementary draft guidance
ODT, 343 KB
This file is in an OpenDocument format
Share this page
The following links open in a new tab
Updates to this page
-
Published consultation outcome.
-
First published.
Sign up for emails or print this page
Update history
2025-06-09 09:30
Published consultation outcome.
2025-01-28 15:53
First published.