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Gibraltar Enacts Pillar 2 Global Minimum Tax

06 January 2025

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Approved Changes

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Gibraltar

Gibraltar enacted the Global Minimum Tax Act 2024 on 23 December 2024. The Act provides for the implementation of a Qualifying Domestic Minimum Top-Up Tax (QDMTT) and an Income Inclusion Rule (IIR) in line with the OECD GloBE Model Rules, which apply for in-scope MNE groups. It does not provide for the implementation of an undertaxed payments/profit rule (UTPR). The QDMTT applies to fiscal years beginning after 31 December 2023, while the IIR applies to fiscal years beginning after 31 December 2024. GloBE Information Returns are required to be filed by the last day of the 15th month following the...