Agenda

OECD RELEASES DETAILED TECHNICAL GUIDANCE ON THE PILLAR TWO MODEL RULES FOR 15% GLOBAL MINIMUM TAX

15/03/2021

OECD released further technical guidance on the 15% global minimum tax agreed in October 2021 as part of the two-pillar solution to address the tax challenges arising from digitalisation of the economy.

The release of the Commentary to the GloBE Rules now provides MNEs and tax administrations with detailed and comprehensive technical guidance on the operation and intended outcomes under the rules and clarifies the meaning of certain terms. The Commentary also illustrates the application of the rules to various fact patterns. The Commentary is intended to promote a consistent and common interpretation of the GloBE Rules that will facilitate co-ordinated outcomes for both tax administrations and MNE Groups.

The OECD/G20 Inclusive Framework on BEPS will develop an Implementation Framework to support tax authorities in the implementation and administration of the GloBE Rules. As the first step in this process, the Inclusive Framework will undertake a public consultation to collect input from stakeholders on the matters they consider need to be addressed as part of the Implementation Framework.

 

Full text of the announcement can be reached from the link below :

https://www.oecd.org/tax/beps/oecd-releases-detailed-technical-guidance-on-the-pillar-two-model-rules-for-15-percent-global-minimum-tax.htm

 

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