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A person is chargeable to multinational top-up tax in the UK¹ if at least one member of a group is allocated a top-up amount and:

1. Ìý

   •ÌýÌýÌýÌý the person is a member of a 'qualifying multinational group' at any time in the period and

2. Ìý

   •ÌýÌýÌýÌý is a UK body corporate or a UK partnership, or

3. Ìý

   •ÌýÌýÌýÌý the person is chargeable to tax in respect of an entity that is member of a qualifying multinational group. This occurs when the responsible member is neither a body corporate nor a partnership that is not a body corporate, is located in the UK, and the profits of the member would be profits of that person for income tax or corporation tax purposes

Some of these terms are defined below. References to 'responsible' members for this definition have been removed by Tolley's Finance Bill Tracking Service, Finance Bill 2025, Sch 4, Pt 2, para 3 so that any UK member can be a chargeable person for UTPR purposes.

A partnership is treated