Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti‑Base Erosion Model Rules (2026)

Addressing the tax challenges arising from the digitalisation of the economy has been a key priority of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the international tax system, recognising that existing rules were no longer fit for purpose in a globalised and digitalised economy. The Global Anti-Base Erosion (GloBE) Rules are a key component of this plan and ensure large multinational enterprise groups (MNE groups) pay a minimum level of tax on their income arising in each of the jurisdictions where they operate. More specifically, the GloBE Rules provide for a co-ordinated system of taxation that imposes a top-up tax on profits arising in a jurisdiction whenever the effective tax rate, determined on a jurisdictional basis, is below the agreed minimum rate. The Commentary to the GloBE Rules was originally released by the Inclusive Framework in March 2022. It explains the intended outcomes under the GloBE Rules, clarifies the meaning of certain terms and illustrates the application of the rules to certain fact patterns. This Consolidated Commentary incorporates Agreed Administrative Guidance that has been released by the Inclusive Framework from March 2022 through January 2026. It provides tax administrations and taxpayers with comprehensive guidance on the interpretation and application of the GloBE Rules in order to promote a consistent and common interpretation and application of those that will facilitate co-ordinated outcomes.