The OECD closed a consultation on the Commentary to support the implementation of the Global Anti-Base Erosion (GloBE) Model Rules contained in Pillar Two of the Framework for the Taxation of the digital economy. Particularly, the Commentary clarifies some terms contained in the GloBE rules, exposes their intended outcomes and illustrates their application to certain fact patterns. The consultation is therefore focused on the tools needed by tax administrations and MNEs to implement GloBE Rules in a consistent, coordinated and efficient manner.
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