G20: Published model rules for Pillar Two domestic implementation of 15% global minimum tax
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Published model rules for Pillar Two domestic implementation of 15% global minimum tax
On 20 December 2021, the Organisation for Economic Co-operation and Development (OECD) published the model rules to support the domestic implementation of Pillar Two of the Framework for the Taxation of the digital economy. Particularly, Pillar Two ensures that all Multinational Enterprises (MNEs) above a global revenue threshold of EUR 750 million are taxed with a minimum rate of 15%, also defined as Global Anti-Base Erosion (GloBE) rules. The model rules support the identification of MNEs falling within the scope of the tax and establish a mechanism for calculating the effective tax rates and the top-up tax. Further, the rules address the treatment of acquisitions and disposals by MNEs and the tuning of administrative aspects, such as filing requirements.
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