Gibraltar

Companies are subject to Gibraltar taxation on income accrued in and derived from Gibraltar.

The standard corporate income tax (CIT) rate is 15% (increasing from 12.5% with effect from 1 July 2024), with utility and energy providers and companies that abuse a dominant position paying a higher rate of 20%. For telecommunications companies, the 15% rate will apply to the gains and profits arising from their non-telecommunications business and activities.

Global Minimum Tax

On 18 December 2024, the Gibraltar government enacted the Global Minimum Tax Act 2024 (the Act). 

The Act imposes a Global Minimum Tax including a Domestic Minimum Top Up Tax compliant with the OECD objectives by direct reference to their Global Anti-Base Erosion Model Rules (Model Rules) and Commentary and for connected purposes.

The Act specifically provides for a Qualifying Domestic Minimum Top-Up Tax (QDMTT) that applies to fiscal years beginning on or after 31 December 2023. The Act also provides for an Income Inclusion Rule (IIR) that applies to fiscal years beginning on or after 31 December 2024. The legislation does not include a Under Tax Profits Rule (UTPR).

The minimum rate for the purposes of the top-up is 15%. The top-up tax will be calculated based on the Model Rules but with modifications.

For more detailed information and the most recent updates, please visit PwC’s Pillar Two Country Tracker.