Gibraltar enacted the Global Minimum Tax Act 2024 on 23 December 2024. The Act provides for the implementation of a Qualifying Domestic Minimum Top-Up Tax (QDMTT) and an Income Inclusion Rule (IIR) in line with the OECD GloBE Model Rules, which apply for in-scope MNE groups. It does not provide for the implementation of an undertaxed payments/profit rule (UTPR).
The QDMTT applies to fiscal years beginning after 31 December 2023, while the IIR applies to fiscal years beginning after 31 Dece…