Gibraltar enacts its global minimum tax law

The bill was published on 10 December 2024 and enacted on 23 December 2024. It follows the OECD GloBE model rules with some changes.

What changed

• Domestic top-up tax: 15% minimum for Gibraltar entities of in-scope groups, including wholly domestic groups, for fiscal years starting on or after 31 December 2023. Investment entities are excluded.
• Income inclusion rule: for fiscal years starting on or after 31 December 2024. Gibraltar has not adopted the undertaxed profits rule.
• Filing: a designated local entity files a GloBE information return in Gibraltar.
• Registration: guidance from the Income Tax Office in December 2025 requires groups with fiscal years ending between 31 December 2024 and 31 August 2025 to register by 28 February 2026, and introduces a local top-up tax return (Form GMTA1).

Who is affected

Gibraltar entities of groups with revenue of at least EUR 750 million.

Sources

• EY: Gibraltar's Pillar Two measures, including qualified domestic top-up tax, now enacted (3 January 2025)
• EY: Gibraltar to introduce Pillar Two registration and local top-up tax return (16 December 2025)
• HMRC: Pillar Two top-up taxes, relevant territories and taxes (Notice 2)