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ARTICLE · 22 JULY 2024

UK Crown Dependencies On Track To Implement Pillar Two Framework For 2025

The governments of Guernsey, the Isle of Man, and Jersey will jointly implement the OECD's Pillar Two framework, establishing a 15% minimum tax rate for large MNEs by 2025, while maintaining competitive investment environments.

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The governments of Guernsey, the Isle of Man and Jersey, at a meeting on 17 May, reaffirmed their commitment to a joint approach to the OECD's Pillar Two framework and noted they would shortly be commencing their respective legislative procedures to a common timeline with introduction for accounting periods commencing on or after 1 January 2025.

Pillar Two establishes the framework for a global 15% minimum effective tax rate for large multinational enterprises (MNEs), calculated at a jurisdictional level, with a top-up charge imposed on any low-taxed profits.

The three Crown Dependencies intend to implement an 'Income Inclusion Rule' and a domestic minimum tax to provide for a 15% effective tax rate for large in-scope MNEs, from 2025, while also remaining committed to continue offering attractive and globally competitive investment environments.

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