MTT09980 - Reference materials: The legislation
Source: gov.uk (2025-08-05)


This page records all legislative events for Multinational Top-up Tax and Domestic Top-up Tax, including primary legislation, regulations, and notices. It will also record releases of draft legislation and legislation included in Finance Bills that is yet to be enacted.

The main legislation which implements MTT and DTT is Finance (No.2) Act 2023. References to 'the Act' in the guidance will be to that Act. Subsequent primary legislation relating to MTT and DTT consists mostly of amendments to that Act. A notable exception is the rules concerning the implementation date of provisions, including where they are subject to the retrospection election of FA25 (see MTT09490 (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt09490)).

The legislation.gov.uk page will note whether there are outstanding amendments to an Act in a banner message. Where this is the case for Finance (No.2) Act 2023, please refer to the most recent Finance Act as well as that Act.

Date

Type

Legislation

Explanatory notes

11 July 2023

Primary

Finance (No.2) Act 2023 (https://www.legislation.gov.uk/ukpga/2023/30/contents), Part 3 (MTT), Part 4 (DTT) and Schedules 14-18

F(No.2)A23 ENs (https://bills.parliament.uk/bills/3435/publications)

22 February 2024

Primary

Finance Act 2024, (https://www.legislation.gov.uk/ukpga/2024/3/contents) Schedule 12 (amendments to F(No.2)A23)

FA24 ENs (https://bills.parliament.uk/bills/3514/publications)

20 May 2024

Notice

Pillar 2 top-up taxes registration (notice 1) (https://www.gov.uk/government/publications/pillar-2-top-up-taxes-registration-notice-1)

None

20 March 2025

Primary

Finance Act 2025 (https://www.legislation.gov.uk/ukpga/2025/8/contents/enacted), Schedule 4 (amendments to F(No.2)A23)

FA25 ENs (https://bills.parliament.uk/bills/3873/publications)

Laid 31 March 2025

Regulations

The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations 2025 (https://www.legislation.gov.uk/uksi/2025/406/made)

Regulation EN (https://www.legislation.gov.uk/uksi/2025/406/made)

Regulation Explanatory Memorandum (https://www.legislation.gov.uk/uksi/2025/406/pdfs/uksiem_20250406_en_001.pdf)

Laid 2 July 2025

The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) (Amendment) Regulations 2025 (https://www.legislation.gov.uk/uksi/2025/783/made)

Regulation EN (https://www.legislation.gov.uk/uksi/2025/783/made)

Regulation Explanatory Memorandum (https://www.legislation.gov.uk/uksi/2025/783/pdfs/uksiem_20250783_en_001.pdf)

24 July 2025

Pillar 2 top-up taxes relevant territories and taxes (notice 2) (https://www.gov.uk/government/publications/pillar-two-top-up-taxes-relevant-territories-and-taxes-notice-2/notice-2-pillar-two-top-up-taxes-relevant-territories-and-taxes)

None

Draft legislation

Further draft legislation was published for consultation on 21 July 2025 as part of Legislation Day 2025. This can be found here (https://www.gov.uk/government/publications/multinational-top-up-tax-and-domestic-top-up-tax-further-amendments).