The UK tax authority, HMRC, has opened a public consultation on the supplementary draft guidance regarding the Multinational Top-up Tax and Domestic Top-up Tax on 28 January 2025.
This release of draft guidance contains sections on flow-through entities, joint ventures, the insurance sector, additional top-up amounts, and other topics. It also contains draft guidance on the undertaxed profits rule (UTPR) and certain other provisions that have been amended or introduced in the current Finance Bill.
HMRC invites comments from stakeholders on this draft guidance, as well as any previously released draft guidance. This will be the final release of draft guidance before publication of the manual.
The consultation will conclude on 8 April 2025.
Earlier, the UK tax authority, His Majesty’s Revenue and Customs (HMRC), released the Explanatory Notes outlining the government amendments, which focus on matters related to Pillar Two, to the Finance Bill 2024-25 on 19 December 2024.