Multinational top-up tax

STOP PRESS relating to new MTT and DTT draft legislation: Clause 19 of, and Schedule 4 to, the draft Finance Bill 2024–25 contains draft legislation amending the current MTT and DTT rules and implementing the Undertaxed Profits Rule (UTPR). Most of the changes to the existing MTT and DTT rules will take effect for accounting periods beginning on or after 31 December 2024 but some provisions will have retroactive effect for accounting periods beginning on or after 31 December 2023. For certain other provisions, taxpayers can elect as to whether a change takes effect for accounting periods on or after 31 December 2023 or for accounting periods beginning on or after 2024. The UTPR will have effect for accounting periods beginning on or after 31 December 2024. The transitional country-by-country reporting safe harbour anti-arbitrage rule, which will prevent groups that have entered into certain hybrid arbitrage arrangements from qualifying for the safe harbour, will have effect from 14 March 2024. HMRC released a policy paper at Autumn Budget 2024 explaining the changes contained in the Finance Bill. For more information, see News

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