Introduction
On 8 October 2021, 136 members of the OECD/G20 Inclusive Frame work 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 December 2021)
- Commentary to the GloBE Rules - First Edition (Published 14 March 2022)
- GloBE Rules Examples (Published 14 March 2022)
- Safe Harbours and Penalty Relief (Published 20 December 2022)
- Agreed Administrative Guidance on the GloBE Rules (Published 2 February 2023)
- Agreed Administrative Guidance on the GloBE Rules (Published 17 July 2023)
- GloBE Information Return(Published 17 July 2023)
- Minimum Tax Implementation Handbook (Published 11 October 2023)
- Administrative Guidance on the Global Anti-Base Erosion Model Rules (Published 18 December 2023)
B - SUPPLEMENTARY REFERENCE MATERIALS
- Summary : Pillar Two Model Rules In A Nutshell
- Pillar Two Model Rules Fact Sheets
- Global Anti-Base Erosion Model Rules Frequently Asked Questions
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