MTT00110 - About this manual: Introduction
Source: gov.uk (2025-08-05)


Notable changes since draft release

The introduction section has been reorganised, with all content on chargeability moved to a new chapter at MTT60000+ (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt60000). Some miscellaneous content has been gathered at MTT09000+ (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt09000), including new pages on the meaning of revenue for the revenue threshold test and the meaning of 'Pillar Two rules apply', and additional information on written consent for the retrospection election for struck-off companies. A section containing reference materials is now at MTT09900+ (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt09900).

A new page on section 273B has been included at MTT27020. (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt27020)

A section on the insurance industry can be found at MTT45400+ (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt45400).

Pages on the self-assessment and information returns have been updated.

Please note that in some sections, page numbers have increased by 10 to accommodate the contents page for the section.

Forthcoming changes to the guidance manual

HMRC is finalising some guidance which will be released shortly, including pages on tax equity partnerships and the remaining investment entity pages, the section on post-filing adjustments, a section of insurance specific guidance for Lloyd's, the page commenting on the interaction between legislation, the guidance manual, and OECD documents, and tables mapping the legislation to OECD documents. Additionally, some examples are being finalised, included some which appeared in draft guidance and have not yet been published in the manual.

The guidance manual will be updated where new legislation is enacted. Please see MTT09980 (https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax/mtt09980) for a reference page containing current legislation, which will also refer to any draft legislation released publicly and legislation contained in bills that are yet to be enacted.

Non-trivial changes to the guidance manual are logged and will be accessible on gov.uk.

Consultation responses

All consultation responses have been recorded. Where a change has not already been made, points are being dealt with in priority order.

If a particular point raised in a consultation response has not been dealt with, stakeholders may wish to request a reply using the consultation inbox. If a point directly affects your business or a client's business and requires a more urgent response, stakeholders may wish to raise this via the compliance inbox (xxx@xxx.xx (mailto:xxx@xxx.xx)).

Although the consultations have now closed, we continue to invite comments on the guidance manual via the consultation inbox.

Gov.uk collection page

Please see the collection page (https://www.gov.uk/government/collections/multinational-top-up-tax-and-domestic-top-up-tax) on gov.uk for previous consultation documents, administrative guidance not contained in the manual, and other policy documents.

Contact us

If you have a technical question about Multinational Top-up Tax or Domestic Top-up Tax, as a taxpayer or agent, you can email the compliance team at xxx@xxx.xx (mailto:xxx@xxx.xx). Improvements to the guidance manual will always be considered as part of the evaluation of technical questions.

Comments specifically on the MTT guidance manual can be sent to xxx@xxx.xx (mailto:xxx@xxx.xx) on an ongoing basis. Please include the page reference number in the email if relevant.