Chapter 8 sets out commentary on the administration of the model rules. Minor changes have been made to the commentary to refer to the four Pillar Two safe harbors that have been agreed by the OECD inclusive framework. Transition rules Chapter 9 provides guidance on transition rules, including r...
This latest release follows the statement on the components of global tax reform, agreed by more than 135 members of the OECD inclusive framework in October 2021, and the subsequent publication of Pillar Two model rules, commentary, safe harbors, and guidance. Components of the Pillar Two rules ...
These Model Rules form part of the so-called BEPS 2.0 Project and provide governments with a template for implementing the Pillar 2 agreement that was reached in October 2021 by 137 jurisdictions in the OECD/G20 BEPS Inclusive Framework. Further guidance in the form of a Commentary and a ...
In early 2022, the OECD will release the Commentary relating to the Model Rules and address co-existence with the US Global Intangible Low-Taxed Income (GILTI) rules. This will be followed by the development of an implementation framework focused on administrative, compliance and co...
According to the MTA 2024 explanatory memorandum, the OECD Pillar 2 Model Rules, its related Commentary, and the OECD Administrative Guidance serve as interpretation aids for the MTA 2024. Accordingly, the Proposals are designed to implement in the MTA 2024 certain topics only covered in the OECD...
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 Administrati...
其中第3(1)款规定，除上下文另有要求外，本法的某些部分（包括实施IIR和UTPR的部分，但不包括实施QDMTT的部分）应与经济合作与发展组织（以下简称为“经合组织”或“OECD”）全球反税基侵蚀（GloBE）立法模板(Model Rules)、注释（Commentary）和征管指南（Administrative Guidance）的规定保持一致，这些规则可能会不时...
The Directive provides a mechanism based on three interdependent model rules commonly referred to as the Global anti-Base Erosion (GloBE), according to which a top-up tax should be collected in instances in which the Effective income Tax Rate (ETR) of a multinational group in a specific jurisd...
We continue to monitor the changes related to the implementation of Pillar 2 rules, and we would be glad to discuss the potential impact of such changes on your business.Download (159 KB) Pillar 2: Release of the Consolidated Commentary to the Global Anti-Base Erosion Model Rules Tax...
Tax Policy Alert OECD releases Pillar Two Commentary and launches public consultation on the Implementation Framework 16 March 2022 In brief The OECD released Commentary and illustrative Examples to the Pillar Two Model Rules (Model Rules) on 14 March 2022. This alert includes several highlights of ...