🇯🇪 🇬🇬 🇮🇲 Tax1 Jan 2025
Jersey, Guernsey and the Isle of Man start taxing large groups at 15%
From 1 January 2025, Jersey, Guernsey and the Isle of Man apply the OECD's 15% global minimum tax to multinational groups with annual revenue of at least EUR 750 million, for fiscal years starting on or after that date. Jersey brought in an income inclusion rule and a multinational corporate income tax, Guernsey made regulations under its income tax law, and the Isle of Man made an order later confirmed by Tynwald. The islands' 0/10 tax regimes continue for everyone else.
The three Crown Dependencies agreed a joint approach to the OECD's Pillar Two rules and implemented them from the same date.
What changed
- Jersey: the Multinational Taxation (Global Anti-Base Erosion – IIR Tax) (Jersey) Law 2025 and the Multinational Corporate Income Tax (Jersey) Law 2025 came into force on 1 January 2025. Jersey is not adopting the undertaxed profits rule for now.
- Guernsey: the Income Tax (Approved International Agreements) (Implementation) (OECD Pillar II) Regulations 2024 came into force on 1 January 2025.
- Isle of Man: the Global Minimum Tax (Pillar Two) Order 2024 applies a domestic minimum top-up tax from 1 January 2025. It was confirmed by an Act of Tynwald in 2025, and amended in July 2026 for the OECD's side-by-side package from 2026.
- In each island, the rules apply to groups with revenue of at least EUR 750 million, for fiscal years starting on or after 1 January 2025.
Who is affected
Island entities of large multinational groups. Most local companies are outside scope and keep their current tax rates.