HM Revenue & Customs (HMRC) has initiated a public consultation on the third version of UK’s Pillar Two global minimum tax rules. Comments must be submitted by 23 October 2024.
HMRC released additional draft guidance for consultation concerning the UK’s adoption of the OECD’s Pillar Two regulations on 12 September 2024. This marks the third iteration of draft guidance from HMRC regarding the UK Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT), with earlier drafts having been issued in June and December of 2023.
This release of draft guidance was published to provide technical guidance on the legislation implementing Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT), in Parts 3 and 4 of Finance (No.2) Act 2023.
Following feedback in this consultation window, finalised pages will be published as a new HMRC manual in autumn 2024.
A supplementary release of draft guidance will be published this winter. This will contain any significant revisions to existing pages, and new pages on flow-through entities, joint ventures, UTPR, tax equity partnerships, post-filing adjustments of covered taxes, and additional top-up amounts. A map between the UK legislation and the OECD documents, and a reverse map, will also be included.
A longer consultation period will follow that release and will be open to responses on any guidance pages (including all previously released draft guidance and published guidance).
