Gibraltar publishes proposed legislation for Pillar Two, including Qualified Domestic Top-up Tax

12 December 2024|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, Global|Gibraltar

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…

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