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Multinational Top-up Tax and Domestic Top-up Tax

The UK is implementing Pillar 2 of the OECD's global minimum tax agreement, which introduces a Multinational Top-up Tax (applying to large multinational enterprises with global revenue over €750m) and a Domestic Top-up Tax (applying to large UK-resident companies). HM Revenue & Customs leads implementation through the Multinational Enterprises (Financial Transparency) Bill, with active consultation on draft guidance and further amendments ongoing.


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4 Apr 2025 | Policy paper HM Revenue & Customs linked

The Multinational Top-up Tax (Pillar 2 territories, qualifying domestic top-up taxes and accredited qualifying domestic top-up taxes) Regulations 2025

This tax information and impact note describes a Statutory Instrument being laid as part of the UK’s implementation of Pillar 2. This Instrument provides a list of Pillar 2 territories, qualifying domestic top-up taxes, and accredited qualifying domestic top-up taxes.

6 Nov 2024 | Policy paper HM Revenue & Customs Context · primary home: Pillar 2 Global Minimum Tax I… linked

Pillar 2: Multinational Top-up Tax and Domestic Top-up Tax amendments

This tax information and impact note is about the amendments being made to the Multinational Top-up Tax and Domestic Top-up Tax, which were brought in as part of the UK's implementation of Pillar 2.

20 Jul 2022 | Policy paper HM Revenue & Customs linked

Introduction of the new multinational top-up tax

In line with the agreement on a 2 Pillar solution to reform the international tax system, this measure will help to ensure multinational enterprises operating within the UK pay a global minimum level of tax.