The taxation changes introduced by the Isle of Man government in November 2024 in response to the OECD’s Pillar 2 Global Minimum Tax Model Rules (GloBE Rules) were granted qualified status by the OECD in August.
The GloBE Rules aim to ensure that the profits of large multinational enterprises (MNEs) are taxed at a minimum effective tax rate of 15% in each of the jurisdictions in which they operate. The rules apply, broadly, to MNE groups with consolidated annual revenue of €750 million.
The OECD has now updated its Central Record of Legislation with Transitional Qualified Status confirming that the Isle of Man’s Pillar Two Domestic Top-up Tax (DTUT) has been accepted as a Qualified DTUT with Safe Harbour status. Its Multinational Top-up Tax (MTUT) has also been confirmed as a Qualified Income Inclusion Rule (IIR).
“This is an important step in our commitment to ensure that our Pillar Two tax regime complies with international tax standards and eases the administrative burden on affected groups as far as possible,” said Isle of Man Treasury Minister Dr Alex Allinson.
“The Treasury continues to monitor developments following the G7 statement on global minimum taxes on 28 June 2025, and will ensure that the Island remains competitive and attractive in terms of business growth, innovation and entrepreneurship.”
The new changes came into force for in-scope groups in respect of Fiscal Years commencing on or after 1 January 2025. The Income Tax Division reminds in-scope MNEs of the requirement to register for Pillar Two tax in the Isle of Man.
