Jurisdiction(s):
United Kingdom

UK Pillar Two (MTT/DTT): scope and qualifying rules for groups and entities, consolidation and multi-parented groups, revenue thresholds, accounting periods, joint ventures and group changes

Published by a LexisNexis Tax expert

Practice notes

STOP PRESS relating to new MTT and DTT draft legislation :

Section 50 and Schedule 8 of the Finance Act 2026 make changes across the MTT and DTT rules. In particular, the draft legislation adopts the OECD’s Administrative Guidance (January 2025), restricting the degree to which pre-entry deferred tax assets and liabilities—arising from tax benefits granted by governments—can be recognised when working out a group member’s effective tax rate, and thus considered in that calculation. That element will be treated as in force for accounting periods ending on or after 21 July 2025. Most other measures will apply to accounting periods beginning on or after 31 December 2025, although certain provisions may, at the election of affected taxpayers, take effect from an earlier date. For more information, see News Analysis: Budget 2025—Tax analysis—International.

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

On 5 August 2025, HMRC published a new MTT and DTT manual. The manual draws on earlier tranches of draft guidance issued for consultation in September 2024 and January 2025, which have been updated to reflect stakeholder comments and feedback received through that process...

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Web page updated on 22/05/2026

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