Revenue eBrief No. 010/26

08 January 2026

Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union

Tax and Duty Manual (TDM) Part 04A-01-02 - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union has been updated in the following sections:

• Section 6.10 - Updates provided in respect of section 111N - Calculation and allocation of UTPR top-up tax amount, as it relates to the practical application of the UTPR allocation key where there is a merger of an entity.
• Section 8.9 - Update provided in respect of section 111AB – Post-filing adjustments and tax rate change, to clarify that a decrease in covered taxes recorded in the financial accounts of a constituent entity in relation to a pre-transition fiscal year should be excluded from the calculation of the ETR and top-up tax in the fiscal year in which the adjustment arises, where the decrease relates to a decrease in current tax expense due to a refund of an overpayment of tax.
• Section 9.8 - Update provided in respect of section 111AJ - Transitional CbCR safe harbour, as it relates to the calculation of simplified covered taxes, to clarify that a decrease in covered taxes recorded in the qualified financial statements that relates to a period prior to the transition period should be excluded, where the decrease relates to a decrease in current tax expense due to the refund of an overpayment of tax.
• Section 9.8.1 - Update provided in respect of section 111AJ - Transitional CbCR safe harbour, as it relates to the change of tax residency of an in-scope entity during a fiscal year.
• Section 10.2 - Update provided in respect of section 111AM – Constituent entities joining and leaving MNE groups or large-scale domestic groups, as it relates to mergers.
• • Section 11.5 - Updates provided in respect of section 111AU - Election to treat investment entity as tax transparent entity, in relation to the determination of whether the tax rate applicable to the constituent entity-owner with respect to the annual changes in the fair value of its ownership interest equals or exceeds the minimum rate.

TDM Part 04A-01-02 - Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union will be further updated in due course to reflect the amendments made to Part 4A by Finance Act 2025.