Legislation recently proposed in Gibraltar includes a domestic top-up tax that first applies to Fiscal Years beginning on or after 31 December 2023.Although earlier announcements by the Government of Gibraltar had indicated that the top-up tax would only apply in 2024 where the parent was in a jurisdiction that had adopted BEPS Pillar Two, that limitation is not included in the proposed legislation.The Income Inclusion Rule would apply for Fiscal Years commencing on or after 31 December 2024, as previously announced. The bill setting out the proposed Global Minimum Tax Act 2024 (the Act) in Gibraltar was published on 10 December...