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MTT45200 | Particular entities and adjustments: Investment entities: Safe harbours

From HM Revenue & Customs · Multinational Top-up Tax and Domestic Top-up Tax

The QDMTT safe harbour and transitional safe harbours apply differently for investment entities than for other members of a group.

QDMTT safe harbour

The QDMTT safe harbour election is made separately for investment entities.

Generally, the normal QDMTT safe harbour rules apply. However, there are variations to the disqualifying conditions for investment entities.

See MTT15130 for further guidance.

Transitional safe harbour

Investment entities are usually excluded from the transitional safe harbour calculations. An exception applies where the investment entity and all the members of the group with a direct ownership interest in the entity are located in the same territory. See MTT15970 for further guidance.