As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on compliance and co-ordination aspects of the Pillar Two global minimum tax.
In October 2021, the international community reached a landmark agreement on a two-pillar solution to reform the international tax rules to address the tax challenges arising from globalisation and digitalisation.
Last December, the Inclusive Framework published the Model Global Anti-Base Erosion (GloBE) Rules. Once implemented into domestic law, the GloBE Rules will provide a co-ordinated system to ensure that Multinational Enterprises (MNEs) with revenues above EUR 750 million pay at least a minimum level of tax – at an effective rate of 15% – on the income arising in each of the jurisdictions in which they operate.
In March 2022, the Inclusive Framework released the Commentary on the GloBE Rules, which provides MNEs and governments with detailed and comprehensive technical guidance on the operation and intended outcomes under the rules.
Following the subsequent public consultation on the Implementation Framework of the global minimum tax, the Inclusive Framework has worked on issues related to administration, operation, compliance and rule co-ordination and is now seeking public input on compliance and co-ordination aspects of the Pillar Two GloBE Rules.
