Pillar Two In Guernsey

Briefing Summary: Guernsey has implemented the OECD’s Pillar Two global minimum tax rules from 1 January 2025, applying to large multinational groups with revenues of €750 million or more. The regime introduces Domestic and Multinational Top-up Taxes to ensure a minimum 15% effective tax rate while preserving Guernsey’s taxing rights. However, most local entities will remain unaffected due to thresholds, exclusions, and limited scope.

Service Area: Trusts and Private Wealth

Location: Guernsey

Guernsey's Pillar Two

The OECD's Two-Pillar Solution to the global risks posed by base erosion and profit shifting in a digital economy ("Pillar Two") saw the introduction of global minimum tax rules designed to ensure that large multinational enterprise groups ("MNE Groups") pay a minimum level of tax on income arising where they operate around the world. In common with the commitments of over 140 other jurisdictions, Guernsey has implemented Pillar Two with effect for accounting