UK: Updates to new guidance manual on Pillar Two

Certain content has been reorganized and some new content has been added

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September 4, 2025

Following the August 5, 2025, publication by HM Revenue and Customs (HMRC) of a new guidance manual on the UK multinational top-up tax (MTT) and domestic top-up tax (DTT) (read TaxNewsFlash), certain content of the annual has been reorganized and some new content added, including guidance on a wholly domestic group or entity entering the scope of MTT at MTT27020 and a section on the insurance industry at MTT45400.

There are still a number of areas outstanding on which guidance has been promised shortly “including pages on tax equity partnerships and the remaining investment entity pages, the section on post-filing adjustments, a section of insurance specific guidance for Lloyd's, the page commenting on the interaction between legislation, the guidance manual, and OECD documents, and tables mapping the legislation to OECD documents.” Some examples are also being finalized.

HMRC say that they continue to invite comments on the guidance manual even though the formal consultations on the draft have closed.

Read a September 2025 report prepared by the KPMG member firm in the UK

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