MTT15980 | Scope: Safe harbours: Transitional safe harbour: Wholly domestic groups and entities

The transitional safe harbour applies for Domestic Top-up Tax purposes in the same way as it does for Multinational Top-up Tax, with some exceptions for wholly domestic groups and entities, in accordance with Section 276 of Finance (No.2) Act 2023.

Wholly domestic groups and entities

Only multinational groups will prepare and file a CbC Report.

For wholly domestic groups and entities, the safe harbour tests can be completed using the figures that would have been in a notional CbC Report. The same rules apply to these groups and entities as they do for other groups that do not prepare a CbC Report. See MTT15930 for further guidance.

Single entities

Single entities will not prepare consolidated financial statements. References to the consolidated statements are to be taken as references to the qualifying financial statements of the single entity.

See MTT09520 for further guidance.