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In line with the OECD’s international tax reform agenda, the UK government has enacted new legislation introducing a 15% global minimum corporate tax rate for large multinational groups.
The move follows the October 2021 Pillar 2 agreement, under which more than 135 countries committed to a minimum level of corporate taxation to curb profit shifting and tax base erosion.
As part of its domestic implementation, the UK has introduced two new levies:
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- Multinational Top-up Tax (MTT)
- Domestic Top-up Tax (DTT)
These taxes apply to accounting periods beginning on or after 31 December 2023, and will ensure that large companies operating in the UK pay at least the minimum 15% effective tax rate — whether their profits arise domestically or abroad.
To support the new regime, a dedicated IT system is under development, and registration is now open for qualifying corporate entities.
Businesses seeking further guidance on the MTT or DTT can direct technical inquiries to HMRC via email.
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