Channel Islands and Isle of Man: Joint statement concerning implementation of Pillar Two global minimum tax

A joint statement describing an agreed approach to implementation of OECD’s Pillar Two global minimum tax framework

Joint statement concerning implementation of Pillar Two global minimum tax

The governments of Guernsey, Jersey, and the Isle of Man issued a joint statement [PDF 190 KB] describing their agreed approach to implementation of the OECD’s Pillar Two global minimum tax framework.

The statement provides that the intention is to implement an income inclusion rule and a domestic minimum tax regime that will only apply to large, in-scope multinational enterprises from 2025 (presumably in respect of accounting periods commencing on or after 1 January 2025, although this is yet to be confirmed).

As a result, members of the largest multinational groups (i.e., those with worldwide revenues of at least €750 million per year) located in Guernsey, Jersey and the Isle of Man would be subject to domestic tax measures aimed at establishing an effective tax rate of 15% on their taxable profits (as calculated in accordance with the global rules).

However, the islands’ 0/10 corporate tax regimes would continue to apply to the vast majority of businesses that do not meet that worldwide revenue threshold.

 

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