Isle of Man

In November 2024, Tynwald approved the Global Minimum Tax (Pillar Two) Order 2024, which comes into force for in-scope groups (MNE groups with annual revenue of Euro 750 million 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 OECD.

Multinational Top-up Tax (MTUT): This tax has been designed such that it will be granted Qualified IIR status and applies in respect of low-taxed MNE profits arising outside the Island.