The OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has released further technical guidance to assist governments with implementation of the global minimum tax under Pillar Two.

Published on 18 December 2023, the Agreed Administrative Guidance for the Pillar Two GloBE Rules (December 2023) supplements the Commentary to the Global Anti-Base Erosion Model Rules. It clarifies how the rules are applied, including guidance on the application of the Transitional Country-by-Country Reporting Safe Harbour and a mechanism for allocating taxes arising in a Blended Controlled Foreign Corporation (CFC) Tax Regime when some of the jurisdictions the multinational operates in are eligible for the safe harbour.

The Inclusive Framework has also released a statement updating the timeline to finalise the text of the Multilateral Convention (MLC) under Pillar One. The timeline recognised that the work to resolve the remaining differences would have to go on into 2024. Nevertheless, members of the Inclusive Framework remained committed to achieve a consensus-based solution and to finalise the text of the MLC by the end of March 2024, with a view to hold a signing ceremony by the end of June 2024


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