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December 21, 2023

Gibraltar announces Pillar Two Qualified Domestic Minimum Top-Up Tax

  • The Government of Gibraltar has announced a Pillar Two-compliant Qualified Domestic Minimum Top-up Tax.
  • This is to apply in respect of fiscal years commencing on or after 31 December 2023 for subsidiaries or permanent establishments of multinational enterprise groups if the Ultimate Parent Entity is in a jurisdiction that has introduced the Pillar Two rules.
  • Full implementation of Pillar Two is planned in respect of financial periods beginning after 31 December 2024.

On 19 December 2023, the Government of Gibraltar announced in a Ministerial Statement and Press Release the introduction of a Pillar Two-compliant Qualified Domestic Minimum Top-Up Tax (QDMTT), which will apply in relation to fiscal years commencing on or after 31 December 2023.

Companies in scope include those belonging to multinational enterprise groups with annual revenue of €750m or more in the consolidated accounts of the Ultimate Parent Entity in at least two of the four immediately preceding accounting periods. The top-up tax is to apply to subsidiaries or permanent establishments of such groups if the Ultimate Parent Entity is in a jurisdiction that has introduced the Pillar Two rules.

This is to be the first part in a two-stage implementation of Pillar Two, with full implementation planned in respect of financial periods beginning after 31 December 2024.

The Press Release states that the QDMTT is to be consistent with the Organisation for Economic Co-operation and Development's (OECD's) Model Rules, Commentary and other relevant guidance issued as at 31 December 2023. The aim is to reduce the risk of interpretive errors and mismatches between jurisdictions, to ensure consistency with Pillar Two adoption in other countries and to meet the standards to qualify as a QDMTT under Pillar Two rules.

The Government of Gibraltar reports that the OECD Secretariat has been consulted on the proposal and that it welcomes the approach taken by Gibraltar.


For additional information with respect to this Alert, please contact the following:

EY Limited Gibraltar

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor


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