Multinational top-up tax

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STOP PRESS relating to new MTT and DTT draft legislation: Section 50 of, and Schedule 8 to, the Finance Act 2026 amends various aspects of the MTT and DTT provisions. Among the changes, the draft legislation incorporates the OECD’s Administrative Guidance (January 2025) on limiting the extent to which pre-entry deferred tax assets and liabilities, arising from tax benefits granted by governments, can be taken into account in determining a group member’s effective tax rate. The latter will be treated as coming into force for accounting periods ending on or after 21 July 2025. The other measures will mostly take effect for accounting periods beginning on or after 31 December 2025, though some provisions may be permitted to take effect from an earlier date at the election of affected taxpayers. For more information, see: News Analysis: Budget 2025—Tax analysis—International.

STOP PRESS relating to new HMRC manual on MTT and DTT: On 5 August 2025, HMRC published a new manual on MTT and DTT. The manual is based on previous tranches of draft guidance released for consultation in September 2024

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