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Chamber Members Briefed on Pillar 2 GloBE Rules: Global Minimum Tax | June 2024

12 June 2024

On 12th June 2024, we hosted an insightful session with David Parsons, Deputy Assessor at the Income Tax Division, who provided an overview of the Pillar 2 GloBE rules and the implications of the Global Minimum Tax.

Key Points Discussed:

  • Global Minimum Tax: Set at 15% for groups with revenue exceeding €750 million
  • Jurisdictional Basis: Effective for accounting periods starting on or after 31 December 2023
  • Tax Allocation Mechanism: Should a jurisdiction with low-taxed profits fail to impose the tax, another jurisdiction will do so through the GloBE rules
  • Isle of Man’s Approach: Introduction of a Qualified Domestic Minimum Top-up Tax (QDMTT) from 2025

Important Announcements:

  • The Isle of Man will implement the QDMTT starting from accounting periods commencing on or after 1 January 2025
  • Decision on the Income Inclusion Rule has been delayed, with minimal expected impact
  • No current plans to implement the Under Taxed Payments Rule (UTPR)

Actions for Impacted Businesses:

  • Engage with Group Tax and Finance departments to understand the group’s position
  • Communicate with the Income Tax Division regarding the drafting legislation, especially if there are specific or unusual circumstances
  • Prepare for new registration requirements and future QDMTT return filing obligations

Next Steps:

  • Drafting of legislation is underway
  • Continued informal engagement with the industry to discuss details
  • Legislation to be presented to Tynwald in Autumn 2024
  • Registration process to begin early to mid-2025
  • The Department for Enterprise (DfE) is actively working on incentives within the Pillar 2 framework

Click here to view the full slide deck. 


This briefing ensures that our members are well-prepared for the impending changes in the global tax landscape. We thank David Parsons for his comprehensive overview and look forward to continued engagement on this important topic.