HMRC have published a new Multinational Top-up Tax and Domestic Top-up Tax internal guidance manual based on previous tranches of draft guidance released for consultation in September 2024 and January 2025, updated to reflect stakeholder comments. The key differences between the previously released draft guidance and the new manual are:
reorganisation of the introduction section, with content on chargeability moved to a new chapter at MTT60000+;
miscellaneous content now gathered at MTT09000+, including new pages on the meaning of ‘revenue’ for the purpose of the revenue threshold test, the meaning of ‘Pillar Two rules apply’, and the retrospection election for struck-off companies;
a new section containing reference materials at MTT09900+;
a new page on F(No 2)A 2023 s 273B included at MTT27020 (this section applies in cases where a wholly domestic group or a single entity is in scope of DTT, but not MTT, and then becomes a multinational group subject to the Pillar Two rules); and
updated pages on self-assessment and information returns.
MTT00110 summarises further updates which are expected to be added to the manual in due course.
Although the consultations on the draft guidance have now closed, HMRC continue to invite comments on the manual via the consultation inbox (pillar2.consultation@hmrc.gov.uk). If a point requires a more urgent response, stakeholders can raise it via the compliance inbox (pillar2mailbox@hmrc.gov.uk).
HMRC have published a new Multinational Top-up Tax and Domestic Top-up Tax internal guidance manual based on previous tranches of draft guidance released for consultation in September 2024 and January 2025, updated to reflect stakeholder comments. The key differences between the previously released draft guidance and the new manual are:
reorganisation of the introduction section, with content on chargeability moved to a new chapter at MTT60000+;
miscellaneous content now gathered at MTT09000+, including new pages on the meaning of ‘revenue’ for the purpose of the revenue threshold test, the meaning of ‘Pillar Two rules apply’, and the retrospection election for struck-off companies;
a new section containing reference materials at MTT09900+;
a new page on F(No 2)A 2023 s 273B included at MTT27020 (this section applies in cases where a wholly domestic group or a single entity is in scope of DTT, but not MTT, and then becomes a multinational group subject to the Pillar Two rules); and
updated pages on self-assessment and information returns.
MTT00110 summarises further updates which are expected to be added to the manual in due course.
Although the consultations on the draft guidance have now closed, HMRC continue to invite comments on the manual via the consultation inbox (pillar2.consultation@hmrc.gov.uk). If a point requires a more urgent response, stakeholders can raise it via the compliance inbox (pillar2mailbox@hmrc.gov.uk).
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