Corporation Top-Up Tax

Overview

On 12 August 2021, Barbados joined the consensus of the OECD/G20 Inclusive Framework on BEPS by agreeing to the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, which had been released on 1 July 2021. The Statement established a new framework for international corporate tax reform, commonly known as the Two-Pillar Solution.

Pillar Two of the OECD/G20 Inclusive Framework's Two-Pillar Solution, known as the Global Anti-Base Erosion (GloBE) Rules, applies to multinational enterprise (MNE) groups with annual consolidated revenues exceeding €750 million. The rules are designed to ensure that these groups pay a minimum effective tax rate of 15% in every jurisdiction where they operate.

If an MNE group's effective tax rate in a jurisdiction falls below 15%, a top-up tax may be applied to bring the rate up to the minimum level. The GloBE Rules aim to reduce profit shifting to low-tax jurisdictions and promote a fairer and more consistent international tax system.

As part of Barbados' adoption of the GloBE Rules, The Barbados Government enacted the Corporation Top-Up Tax Act, 2024-16.

Legislation

• Corporation Top-up Tax Act, 2024-16
• Corporation Top-Up Tax (Designation of Competent Authority and GloBE information Returns) Regulations 2026

Agreement

• Agreement

Announcements 

• Experts Outline Key Corporation Top-Up Tax Compliance Requirements (May 27,2026)
• BRA Releases Guidance Documents on Corporation Top-Up Tax (June 11, 2026)
• Payment of the Top-Up Tax (June 19, 2026)
• Top-Up Tax: Filing of the Notification and the GloBE Information Return (GIR) (June 19, 2026)

Guidance

The guidance notes issued are:

• Qualified Domestic Minimum Top-up Tax (QDMTT) Safe Harbour (June 11, 2026)
• Country-by-Country Reporting (“CbCR”) Transitional Safe Harbour (June 11, 2026)
• De Minimis Exclusion (June 11, 2026)
• GIR and Foreign Lodgment Notification (June 11, 2026)
• Payment of Top-Up Tax (GloBE Minimum Tax) (June 11, 2026)
• Waiver of Penalties and Interest for the Filing of Corporation Top-Up Tax Notifications and GloBE Information Returns (“GIR”) and Payment of Corporation Top-Up Tax (June 29, 2026)

Return Documents and Supporting Schedule

The following documents are intended to guide users with the filing and payment of the Top-Up Tax.

• Top-Up Tax Filing & Payment Guide
• Barbados MNE Group Entity Template: Please complete the Excel form and upload it as a Supporting Document on the ‘Documents’ page of your Top-Up Tax return in TAMIS. 

This document is intended to guide users through the GloBE Information Return (GIR) registration, Notification Filing and GIR Filing process in the Automatic Exchange of Information (AEOI) portal.

• User Manual for GIR for MNE Groups in Barbados