On 28 January 2025, HMRC released for consultation supplementary draft guidance in relation to the UK's implementation of the OECD's Pillar Two rules. This is the fourth tranche of draft guidance published by HMRC in relation to UK Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT). Previous tranches were published in June 2023, December 2023 and September 2024.
Consultation responses have been invited on both the latest and previously released draft guidance (as well as suggestions for any other content that might be helpful) on or before 8 April 2025, following which the guidance manual will be published in full in late spring 2025. HMRC have confirmed that this will be the last draft guidance document released as a consultation document, but comments on guidance after publication of the manual would still be welcome via HMRC’s Pillar Two dedicated inbox.