Isle of Man

Pillar Two

In November 2024, Tynwald approved the Global Minimum Tax (Pillar Two) Order 2024, which comes into force for in-scope groups (i.e. multinational enterprise [MNE] groups with annual revenue of 750 million euros [EUR] or more in the Consolidated Financial Statements of the Ultimate Parent Entity) in respect of fiscal years commencing on or after 1 January 2025. The Global Minimum Tax (Pillar Two) Order 2024 implements the following in the Island:

• A 15% Domestic Top-up Tax (DTUT): This tax has been designed such that it should achieve Qualified Domestic Minimum Top-up Tax (QDMTT) Safe Harbour status with the Organisation for Economic Co-operation and Development (OECD).
• Multinational Top-up Tax (MTUT): This tax has been designed such that it will be granted Qualified Income Inclusion Rule (IIR) status and applies in respect of low-taxed MNE profits arising outside the Island.