The OECD/G20 Inclusive Framework on BEPS has released further technical guidance on the 15% global minimum tax agreed in October 2021 as part of the two-pillar solution to address the tax challenges arising from digitalisation of the economy. The commentary elaborates on the application and operation of the Global Anti-Base Erosion (GloBE) Rules agreed and released in December 2021. The GloBE Rules provide a co-ordinated system to ensure that multinational enterprises (MNEs) with revenues above EUR 750 million pay at least a minimum level of tax – 15% – on the income arising in each of the jurisdictions in which they operate.

The release of the commentary to the GloBE Rules now provides MNEs and tax administrations with detailed and comprehensive technical guidance on the operation and intended outcomes under the rules and clarifies the meaning of certain terms. It also illustrates the application of the rules to various fact patterns. The commentary is intended to promote a consistent and common interpretation of the GloBE Rules that will facilitate co-ordinated outcomes for both tax administrations and MNE Groups.

The OECD/G20 Inclusive Framework on BEPS will now develop an implementation framework to support tax authorities in the implementation and administration of the GloBE Rules. As the first step in this process, the Inclusive Framework will undertake a public consultation to collect input from stakeholders on the matters they consider need to be addressed as part of the implementation framework.

To access the full text of the GloBE Rules and its commentary, visit


(Source: OECD Tax)

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