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...
The OECD inclusive framework will continue to publish administrative guidance on further Pillar Two topics, including, for example, the deferred tax liability recapture rules and deferred tax arising in relation to the profits of other constituent entities such as CFCs or permanent establishments. More ...
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 GloB...
Implementation of additional OECD Guidance 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...
Pillar 2 implementing EU Directive on December 22, 2021. The OECD is set to provide more guidance in the form of a Commentary and a Pillar 2 implementation framework during the course of 2022 and, moreover, publish a model provision for a Subject to Tax Rule together with a multilateral ...
In March 2022, the OECD released technical guidance on its 15% global minimum tax agreed as the second ‘pillar’ of a project to address the tax challenges arising from digitalisation of the economy. This guidance elaborates on the application ...
OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors; Public consultation document on Amount B of Pillar One; Pillar Two Subject to Tax Rule (STTR); Pillar Two GloBE information return; and The second set of Pillar Two administrative guidance. ...
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
The document aims to provide tax administrations and taxpayers with guidance on the common interpretation and application of the GloBE Rules. Please follow the link below to access the Consolidated Commentary: https://www.oecd.org/publications/tax-challenges-arising-from-the-digitalisation-of-the-econo...