On February 11, 2025, the Isle of Man Official Gazette published online the consolidated text of the Global Minimum Tax, in line with Pillar Two of OECD Guidelines on transfer pricing rules.
To access the text, click here.
On November 27, 2024, the Isle of Man Income Tax Division announced the implementation of the OECD’s Pillar Two global minimum tax rules by the means of the Statutory Document No. 2024/0234. These rules, that will take effect as of January 1, 2025, apply to multinational enterprise (MNE) groups which have an annual income exceeding €750 million (US$793 million). The framework includes the Income Inclusion Rule (IIR) and a Qualified Domestic Minimum Top-up Tax (DTUT) but excludes the Undertaxed Payments Rule (UTPR). It provides guidelines for domestic entities, including tax currency conversions, and excludes certain foreign and domestic taxes when calculating adjusted taxes. The document also establishes methods for allocating top-up tax liabilities among entities and sets strict deadlines with penalties for information return compliance. This initiative aims to ensure large MNEs meet a minimum 15% tax threshold globally, aligning with OECD standards.
To access the Statutory Document, click here.