HMRC consulting on MTT and DTT draft guidance

HMRC are seeking views on supplementary draft guidance for multinational top-up tax and domestic top-up tax which includes sections on flow-through entities joint ventures (JV) the insurance sector and additional top-up amounts. The draft also covers the undertaxed profits rule (UTPR) and other provisions amended or introduced in Finance Bill 2025.

Although the updated draft guidance now covers the applicability of the rules to JV groups including the background on what constitutes a JV group calculating top-up amounts and chargeability under MTT and DTT there are fewer detailed examples than some practitioners would like. Stephanie Mullins Slaughter and May says: ‘Given how fact-specific the application of the rules is I had (perhaps optimistically) hoped that the guidance would contain a number of examples with different fact patterns which could be used as a basis to take the reader through...