Multinational Top-up Tax and Domestic Top-up Tax

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.

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