HMRC has issued new draft guidance on the multinational and domestic top-up taxes (introduced in Finance (No 2) Bill 2023 Parts 3 and 4). This initial draft includes the following three chapters, which are expected eventually to be included a new HMRC multinational top-up tax guidance manual:
introduction and overview of the new taxes with guidance on chargeability;
scope of the taxes, including guidance on excluded entities, the revenue threshold test and the transitional country-by-country reporting safe harbour; and
administration.
Paragraph 09990 provides a convenient table setting out how the UK multinational top-up tax Finance (No 2) Bill 2023 legislation relates to the OECD model rules and guidance.
The new draft guidance is intended to cover both taxes. Given that many of the new rules are common to both taxes, the guidance aims to make clear where there is a different application for domestic top-up tax compared to multinational top-up tax. HMRC is consulting on the draft until 12 September 2023.
HMRC has issued new draft guidance on the multinational and domestic top-up taxes (introduced in Finance (No 2) Bill 2023 Parts 3 and 4). This initial draft includes the following three chapters, which are expected eventually to be included a new HMRC multinational top-up tax guidance manual:
introduction and overview of the new taxes with guidance on chargeability;
scope of the taxes, including guidance on excluded entities, the revenue threshold test and the transitional country-by-country reporting safe harbour; and
administration.
Paragraph 09990 provides a convenient table setting out how the UK multinational top-up tax Finance (No 2) Bill 2023 legislation relates to the OECD model rules and guidance.
The new draft guidance is intended to cover both taxes. Given that many of the new rules are common to both taxes, the guidance aims to make clear where there is a different application for domestic top-up tax compared to multinational top-up tax. HMRC is consulting on the draft until 12 September 2023.
