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Multinational Top-up Tax and Domestic Top-up Tax

Source
HM Revenue & Customs - Activity
Source link
https://www.gov.uk/hmrc-internal-manuals/multinational-top-up-tax-and-domestic-top-up-tax
Published
2026-08-10 15:22:50
Discovered by ProcIntel
2026-08-10 18:12:56
Category
Regulation, Tariffs, Sanctions & Trade
Geography
UK
Organisations
Review status
Pending
Record type
REAL

Summary

This manual covers Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT). MTT is the UK's implementation of the Income Inclusion Rule and Undertaxed Profits Rule. These are widely known as the GloBE rules, as set out in the OECD's Pillar Two Model Rules. DTT is the UK's implementation of a Qualifying Domestic Minimum Top-up Tax (QDMTT), which applies the Pillar Two rules to UK entities.

Procurement Relevance Gate

FAIL — score 7.0/100 — evaluated 2026-08-10 18:12:56
Only geographic exposure matched — no substantive content indicator, so this cannot pass alone.
  • geographic_exposure (weight 8) — matched on "1 linked geography"

Initial Signal Assessment ProcIntel's automatic, provisional read of this individual Signal -- Initial Significance and Initial Confidence, computed deterministically before any Event extraction or human review.

A provisional, automatically-computed reading of this individual Signal, before Event extraction or human review. Not a final rating.

Not Assessed — this Signal did not pass the Procurement Relevance Gate, or is fictional/excluded test data.