Multinational top-up and domestic top-up taxes: further draft guidance

HMRC has published further draft guidance on the multinational top-up tax and domestic top-up tax. This release includes all previously released pages (including updates in some cases) in addition to newly drafted pages. For further information, including an overview of which pages are new or significantly revised, see the introduction in the document.

HMRC invites comments from stakeholders on this draft guidance. Please email responses to the inbox: pillar2.consultation@hmrc.gov.uk. Include the page reference number in responses where applicable.

Publication of the manual will begin following the review of consultation responses. A supplementary release of draft guidance will follow in due course. This will include remaining draft guidance on flow-through entities, joint ventures, the insurance sector, additional top-up amounts, and the undertaxed profits rule.

A final release of draft guidance is expected by December, which will include an updated map of the OECD documents as they relate to UK legislation. HMRC will begin to publish finalised pages as an HMRC manual prior to that.