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Multinational Top-up Tax and Domestic Top-up Tax: Supplementary draft guidance

We welcome views on this supplementary release of draft HMRC guidance for Multinational Top-up Tax and Domestic Top-up Tax.

Last fetched 03 May 2026 · gov.uk
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HMRC has published a document of supplementary draft guidance on Multinational Top-up Tax and Domestic Top-up Tax.

This release of draft guidance contains sections on flow-through entities, joint ventures, the insurance sector, additional top-up amounts, and other topics. It also contains draft guidance on the undertaxed profits rule (UTPR) and certain other provisions that have been amended or introduced in the current Finance Bill.

HMRC invites comments from stakeholders on this draft guidance, as well as any previously released draft guidance. This will be the final release of draft guidance before publication of the manual.

You can access previous releases of draft guidance on GOV.UK.

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