Isle of Man Issues Updated Global Minimum Tax Order

On June 19, 2025, the updated version of the Global Minimum Tax (Pillar Two) Order 2024 was published. 

There are minor updates to the previous law. 

Section 7(4) of the law states that in applying the IIR and QDMTT, the provisions of the GloBE Rules must be applied consistently with the most recent:

(a) GloBE Commentary;

(b) Administrative Guidance; and

(c) Safe Harbours,

that have been applied in the Isle of Man before the start of the Fiscal Year that is being considered.

The previous law included the OECD Administrative Guidance up to and including the June 2024 OECD Administrative Guidance. The updated law amends the definition of Administrative Guidance in Section 3(2) of the law to also include:

-January 2025 Central Record of Legislation with Transitional Qualifying Status (applies in respect of any Fiscal Year that begins on or after June 17, 2025 and is deemed to have been in operation from the beginning of any Fiscal Year that began on January 1, 2025 or any subsequent day prior to June 17, 2025)

-January 2025 OECD Administrative Guidance on Article 8.1.4 and 8.1.5 of the Model Rules 

-January 2025 OECD Administrative Guidance on Article 9.1 of the Model Rules

The January OECD Administrative Guidance on Articles 8.1.4, 8.1.5 and 9.1 applies in respect of any Fiscal Year beginning on or after June 17, 2025. 

Article 62(2) of the Law has also been amended to provide that the Treasury may prescribe  the Safe Harbour status of another jurisdiction’s Qualified Domestic Minimum Top-up Tax.