On 17 June 2024, theOECD/G20 Inclusive Framework on BEPS(“OECD inclusive framework”) published further administrativeguidanceon the implementation of the Pillar Two global minimum tax rules ("Pillar Two"), together with details of the processes for determining that jurisdictions' local implementation...
Administrative guidance was released in February 2023 on allocating blended CFC taxes (such as US GILTI (global intangible low-taxed income)) to group entities for the purposes of the Pillar Two calculations using a formulaic approach based on “blended CFC allocation keys.” Further guidance has ...
Tax Policy Alert OECD releases Administrative Guidance on the Pillar Two Global Minimum Tax Rules 7 February 2023 In brief The OECD released Administrative Guidance ('guidance') on the Pillar Two Global Anti-Base Erosion Rules (GloBE Rules) on 2 February. The guidance was approved by the OECD/...
OECD Administrative Guidance Addresses Key Pillar 2 Technical IssuesJenn, Brian H.Lockhart, Jonathan D.Lu, Elizabeth C.Le ChenInternational Tax Journal
Summary of OECD Pillar 2 Guidance The documents released on December 20, 2022 are: Guidance on Safe Harbors and Penalty Relief A public consultation document on the GloBE Information Return and A public consultation document on Tax Certainty for the Glo...
Since that agreement was reached, the Inclusive Framework has released a series of significant agreed documents on the global minimum tax under Pillar Two, including the GloBE Model Rules,2 Commentary to the GloBE Model Rules,3 guidance on GloBE Safe Harbors,4 three packages of GloBE Administrative...