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: * How many of these groups are subject to the Domestic Top-Up Tax (DTUT); * 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,

Data Tables (1)

Full Response Text

Freedom of Information
Seyrsnys Fysseree

The Treasury Government Office,
Douglas Isle of Man, IM1 3PU

Telephone: (01624) 685605 Email: FOI.Treasury@gov.im

Government Website: www.gov.im

Our ref: 4904222 29 September 2025

Dear ###,

We write further to your request, received 2 September and amended on 24 September, which states:

"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,"

Our response to your request is as follows, which provides the information for both parts of your request:

It is not possible for Treasury to definitively determine at this stage the number of multinational enterprise (MNE) groups that will be within scope of the Isle of Man’s Pillar Two Global Minimum Tax legislation. However information held by the Treasury,

at the time this request was received, has estimated that circa 200 MNE Groups are likely to be in-scope of the Isle of Man’s Domestic Top-up Tax (DTUT) and fewer than 10 MNE Groups will be in scope of the Island’s Multinational Top-up Tax (MTUT). It should be noted that the Isle of Man has not introduced an Undertaxed Profits Rule – the MTUT is an Income Inclusion Rule only.

By way of advice and assistance all groups that are ultimately in-scope of the Isle of Man Pillar Two legislation will be subject to DTUT. However, the number of groups that will ultimately pay DTUT in any one year will depend in particular upon their profitability and the applicability of the de-minimis exclusions. Treasury expect the MTUT to impact very few Isle of Man businesses.

Furthermore there is some additional information in the public domain which you may be interested in. The information relates to a Tynwald Members Briefing on Global Minimum Tax (Pillar Two) Order 2024 and can be found at the following web link, from the Tynwald Publication Diary and Circulars page:

https://www.tynwald.org.im/spfile?file=/about/MemberCirculars/20241108%20Tynwal d%20Members%20Briefing%208%20Nov%2024%20Global%20Minimum%20Tax%20 PDF.pdf

Please quote the reference number 4904222 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im.

Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.