On 31 October 2023, Mrs. Marlene Nembhard-Parker, Deputy Commissioner General, Legal Support Services of Tax Administration Jamaica said that Jamaica plans to introduce a Qualified Domestic Minimum Top-up Tax (QDMTT) under the OECD Pillar 2 Global Minimum Tax rules. Mrs. Marlene Nembhard-Parker stated this at a Washington conference organized by the U.S. Council for International Business and the OECD.
The QDMTT allows the jurisdiction to apply a top-up tax to the local excess profits of the MNE Group where those profits are subject to an overall effective tax rate (ETR) that is below 15%. The imposition of this additional tax will not alter the overall after-tax cost of the investment for the MNE Group because the MNE Group would simply have been subject to the same tax liability in another jurisdiction pursuant to an IIR or UTPR.