Multinational top-up tax

STOP PRESS relating to new MTT and DTT draft legislation: Clause 50 of, and Schedule 8 to, the Finance Bill 2026 (as introduced) contains draft legislation amending various aspects of the MTT and DTT provisions. Amongst 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. To track the progress of the Finance Bill and any changes to the draft legislation, see: Tax—Finance Bill 2026 tracker—progress through Parliament.

STOP PRESS relating to new HMRC manual on MTT and DTT: On 5

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