Multinational and Domestic Top-up Taxes (UK Pillar Two): Glossary of Defined Terms, Legislative Sources and 2025–2026 Updates

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STOP PRESS relating to new MTT and DTT draft legislation :

Section 50 and Schedule 8 of the Finance Act 2026 revise multiple elements of the MTT and DTT rules. Notably, the draft law folds in the OECD’s Administrative Guidance (January 2025), which curbs how far pre-entry deferred tax assets and liabilities—stemming from government-granted tax incentives—may be recognised when calculating a group member’s effective tax rate. That element is to be regarded as effective for accounting periods ending on or after 21 July 2025. Most remaining measures apply to periods beginning on or after 31 December 2025, albeit certain provisions may commence earlier at the option of impacted taxpayers. For further detail, see: News Analysis: Budget 2025—Tax analysis—International. These commencement dates apply to the specified measures under the MTT and DTT regimes as set out in the draft legislation and Finance Act 2026, as applicable thereafter.

STOP PRESS relating to new HMRC manual on MTT and DTT :

On 5 August 2025, HMRC issued a new MTT and DTT manual. It draws on earlier tranches of draft guidance circulated for consultation in September 2024 and January 2025, subsequently revised to incorporate stakeholder feedback. The main differences between the previously issued...

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Web page updated on 22/05/2026

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