Policy paper

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.

• From: HM Revenue & Customs
• Published: 20 July 2022

Documents

Multinational top-up tax: UK adoption of Organisation for Economic Co-operation and Development Pillar 2

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Draft legislation

PDF, 4.57 MB, 116 pages

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Draft legislation accessible version

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Explanatory note

ODT, 214 KB

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Details

The measure will introduce a new tax on UK parent members within a multinational enterprise group. A top-up tax will be charged on UK parent members when a subsidiary is located in a non-UK jurisdiction, and the group’s profits arising in that jurisdiction are taxed at below the minimum rate of 15%.

This is in accordance with the agreement to reform the international tax framework made by the G20 — Organisation for Economic Co-operation and Development Inclusive Framework on Base Erosion and Profit Shifting (BEPS) on 8 October 2021.

Read the consultation and summary of responses.

Published 20 July 2022