Introduction
On 8 October 2021, 136 members of the OECD/G20 Inclusive Framework on Base Erosion Profit Shifting (BEPS) have joined the Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. The Two-Pillar Solution is comprised of Pillar One and Pillar Two. Pillar One aims to ensure a fairer distribution of profits and taxing rights among countries with respect to the largest multinational enterprises (MNEs). Meanwhile, Pillar Two puts a floor on tax competition on corporate income tax through the introduction of a global minimum corporate tax rate that countries can use to protect their tax bases. The Global Anti-Base Erosion (GloBE) Rules are the main Pillar Two Rules which set out the scope and mechanism of the new global minimum effective tax rate (ETR) of 15%. A top-up tax will be charged when the group’s ETR in a jurisdiction falls below the 15% level.
A - MAIN REFERENCE MATERIALS
- Model GloBE Rules (Published 20/12/2021)
- Commentary to the GloBE Rules :
- First Edition (Published 14/03/2022)
- Consolidated Commentary (2023) (Published 25/04/2024)
- Consolidated Commentary to Model GloBE Rules (Published 09/05/2025)
- Agreed Administrative Guidance (AAG):
- Safe Harbours and Penalty Relief (Published 20/12/2022)
- AAG published on 02/02/2023
- AAG published on 17/07/2023
- AAG published on 18/12/2023
- AAG published on 17/06/2024
- AAG published on 15/01/2025 (Article 8)
- AAG published on 15/01/2025 (Article 9)
- AAG published on 05/01/2026 (Side-by-Side Package)New!
- Guidance on the GloBE Information Return (GIR):
B - SUPPLEMENTARY REFERENCE MATERIALS
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