On November 26, 2024, Guernsey authorities published guidelines on implementing the OECD’s GloBE rules under Pillar Two. The new rules establish a 15% global minimum tax for multinational enterprise (MNE) groups with an annual consolidated turnover of at least €750 million (US$777 million) in two of the last four fiscal years. In addition, they establish criteria for domestic and multinational top-up taxes under the income inclusion rule (IIR) and require MNEs to appoint a resident entity for filing obligations. The rules also clarify recordkeeping and filing requirements for GloBE, domestic top-up, and multinational top-up tax returns. Submissions must be made within 15 months of the fiscal year-end, or 18 months for the first year of liability.