Pillar Two Global Minimum Tax - Number of In-Scope Companies

Summary

The request sought the number of multinational enterprise groups in scope of the Isle of Man's Pillar Two Global Minimum Tax and a breakdown of those subject to Domestic or Multinational Top-Up Taxes. The Treasury responded that exact numbers cannot be definitively determined but provided estimates of circa 200 groups for the Domestic Top-Up Tax and fewer than 10 for the Multinational Top-Up Tax.

Key Facts

• The Treasury cannot definitively determine the exact number of MNE groups in scope at this stage.
• Estimates suggest circa 200 MNE groups are likely in scope of the Domestic Top-Up Tax (DTUT).
• Fewer than 10 MNE groups are expected to be in scope of the Multinational Top-Up Tax (MTUT).
• The Isle of Man has not introduced an Undertaxed Profits Rule; the MTUT is an Income Inclusion Rule only.
• The number of groups ultimately paying DTUT depends on profitability and de-minimis exclusions.

Data Disclosed

• circa 200
• fewer than 10
• 2025-09-02
• 2025-09-29
• 24 September
• 2024
• 4904222

Original Request

Dear Sir/Madam,

I am writing to request information under the Freedom of Information Act 2015.

Please could you provide the following information:

1. The number of multinational enterprise (MNE) groups currently identified as being within scope of the Pillar Two Global Minimum Tax framework in the Isle of Man, as per the Global Minimum Tax (Pillar Two) Order 2024.

2. If available, a breakdown of:

3. How many of these groups are subject to the Domestic Top-Up Tax (DTUT);
4. How many are expected to be subject to the Multinational Top-Up Tax (MTUT) (Income Inclusion Rule or Undertaxed Profits Rule).

If the information requested is already publicly available, I would be grateful if you could direct me to the appropriate resource.

Please do not hesitate to contact me should you require any clarification regarding this request. I look forward to your response.

Yours faithfully,