Section 121 Introduction to multinational top-up tax

United Kingdom

(1)

The purpose of this Part is to implement the provisions of the Pillar Two rules relating to top-up tax under the F1IIR and UTPR (within the meaning of the Pillar Two rules).

(2)

For that purpose, this Part makes provision for a tax payable in respect of members of multinational groups who are located in territories (outside the United Kingdom) where their rate of tax (as determined in accordance with this Part) is less than 15%.

(3)

The tax is to be known as “multinational top-up tax”.

(4)

Sections 122 to 124 set out the charge to multinational top-up tax and describe how it is to be calculated.

(5)

Chapter 2 of this Part—

(a)

sets out the meaning of “multinational group”;

(b)

describes who the members of such a group are;

(c)

identifies the ultimate parent of such a group;

(d)

limits the application of this Part to multinational groups with an annual revenue of at least 750 million euros and that have at least one member in the United Kingdom (such a group is referred to in this Part as “qualifying”);

F2(e)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Annotations

Textual amendments

F1: Words in s. 121(1) substituted (n relation to accounting periods commencing on or after 31.12.2024) by Finance Act 2025 (c. 8), Sch. 4 paras. 2(2), 10
F2: S. 121(5)(e) omitted (in relation to accounting periods commencing on or after 31.12.2024) by virtue of Finance Act 2025 (c. 8), Sch. 4 paras. 2(3), 10

Notes on Part 3

Modifications

C1: Pt. 3 modified (2.12.2025) by Finance Act 2026 (c. 11), Sch. 8 paras. 32, 53(3)