Global Anti-Base Erosion Model Rules (Pillar Two)
A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground breaking plan to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy. The Global Anti-Base Erosion Rules (GloBE) are a key component of this plan and ensure large multinational enterprise pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.
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GloBE Model Rules
Published 20 December 2021
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- English
- Français (Publié le 7 février 2023)
- Español (Publicado el 1 de abril 2026)
- Deutsch (Veröffentlicht am 28. Februar 2023)
- Русский (опубликовано 10 ноября 2025 г.)
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 minimum rate. This publication delineates the scope and sets out the operative provisions and definitions of the GloBE Rules. These rules are intended to be implemented as part of a common approach and to be brought into domestic legislation as from 2022.
Commentary to the GloBE Rules
Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2025)
Published 9 May 2025
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This Consolidated Commentary incorporates Agreed Administrative Guidance that has been released by the Inclusive Framework since March 2022 up until March 2025.
Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two), First Edition
Administrative Guidance
January 2026
Side-by-Side package
Published 05 January 2026
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This document sets out the Side-by-Side package, which consists of:
- Simplifications consisting of a safe harbour based on a simplified ETR computation (Simplified ETR Safe Harbour), as well as a one-year extension of the Transitional CbCR Safe Harbour.
- A Substance-based Tax Incentives Safe Harbour, which allows for certain Qualified Tax Incentives (i.e. expenditure-based and certain production-based tax incentives) to be treated as an addition to covered taxes, up to a certain amount based on substance.
- The Side-by-Side System, which consists of two safe harbours that apply to MNE Groups headquartered in jurisdictions recognised by the Inclusive Framework as having an eligible tax regime. The Side-by-Side (SbS) Safe Harbour exempts those MNE Groups from the IIR and UTPR in other jurisdictions, whereas the UPE Safe Harbour only exempts the UPE jurisdiction from the UTPR. The Side-by-Side System leaves QDMTTs unaffected.
- An evidence-based stocktake process to ensure a level playing field is maintained for all Inclusive Framework Members.
On 13 January 2026, the OECD held a technical webinar where OECD experts presented the key elements of the Side-by-Side package and outlined what lies ahead, including further simplifications, capacity-building efforts and additional resources for implementing jurisdictions and affected taxpayers. The replay is available on the event page.
June 2024
Published 17 June 2024
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This document sets out the fourth set of Administrative Guidance items released by the Inclusive Framework, following the first, second and third sets of Administrative Guidance items that were published in February 2023, July 2023 and December 2023 respectively. This fourth set of guidance supplements the Commentary to the Global Anti-Base Erosion Model Rules in order to clarify their application, including guidance on application of the recapture rule applicable to deferred tax liabilities (DTL), cross-border allocation of current and deferred taxes, allocation of profits and taxes in certain structures involving Flow-through Entities, and the treatment of securitisation vehicles.
December 2023
Published 18 December 2023
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This document sets out the third set of Administrative Guidance items released by the Inclusive Framework, following the first and second sets of Administrative Guidance items that were published in February 2023 and July 2023 respectively. This third set of guidance supplements the Commentary to the Global Anti-Base Erosion Model Rules in order to clarify their application, 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 MNE operates in are eligible for the safe harbour.
July 2023
Published 17 July 2023
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- English
- Français (lire le résumé)
- Italiano (pubblicato il 7 ottobre 2024)
- Deutsch (veröffentlicht am 19. Dezember 2024)
This document sets out the second set of Administrative Guidance items released by the Inclusive Framework, following the first set of Administrative Guidance items that were published in February 2023. This second set includes guidance on currency conversion rules when performing GloBE calculations, on tax credits, and on the application of the Substance-based Income Exclusion (SBIE). It also includes further guidance on the design of Qualified Domestic Minimum Top-up Taxes (QDMTT) as well as two new safe harbours:
- A permanent safe harbour for jurisdictions that introduce a Qualified Domestic Minimum Top-up Tax (QDMTT), which will make compliance and administration easier for MNEs and tax administrations.
- A transitional safe harbour, which provides the UPE Jurisdiction with relief from the application of the UTPR for fiscal years commencing on or before the end of 2025
February 2023
Published 2 February 2023
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- Italiano (pubblicato il 28 febbraio 2024)
- Français (lire le résumé)
- Deutsch (veröffentlicht am 14. Juni 2024)
The items of Administrative Guidance set out in this document address a wide range of issues that Inclusive Framework members have identified as the issues most in need of immediate clarification and simplification for stakeholders. In particular, this document addresses issues related to the scope, the income and taxes calculation as well as issues related to insurance companies. It also provides guidance on the transition rules and the design of Qualified Domestic Minimum Top-up Taxes (QDMTT).
Central Record for purposes of the Global Minimum Tax
Explore the dedicated page for the central record for purposes of the Global Minimum Tax.
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GloBE Information Return
The GloBE Information Return sets out a standardised information return to facilitate compliance with and administration of the GloBE Rules. It contains the information a tax administration needs to perform an appropriate risk assessment and to evaluate the correctness of a Constituent Entity’s Top-up Tax liability. This document has been developed following a public consultation that took place in March 2023. In response to feedback, the GIR incorporates transitional simplified reporting requirements that allow MNEs to report their GloBE calculations at a jurisdictional level. The GIR will be subject to coordinated filing and exchange mechanisms that allow MNEs to report their GloBE calculations on a single return, where the more detailed information is made available to implementing jurisdictions where a Top-up Tax liability may arise.
GloBE Information Return
GloBE Information Return XML Schema: User Guide for Tax Administrations (January 2025)
GloBE Information Return (Pillar Two) Status Message XML Schema: User Guide for Tax Administrations (July 2025)
Multilateral Competent Authority Agreement on the Exchange of GloBE Information (January 2025)
Compilation of additional GloBE information reporting requirements
Updated 22 July 2025
This page provides a compilation of the additional information reporting requirements introduced by Inclusive Framework Member jurisdictions that have implemented the Income Inclusion Rule, the UTPR and/or a Qualified Domestic Minimum Top-up Tax.
Safe harbours and penalty relief
Published 20 December 2022
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Building on the input from a public consultation in April 2022, the Inclusive Framework has agreed on the design of a transitional safe harbour and a regulatory framework for the development of a potential permanent safe harbour as well as a common understanding for a transitional penalty relief regime.
Illustrative examples
Published 9 May 2025
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These examples illustrate the application of the Model GloBE Rules to certain fact patterns. Originally published on 14 March 2022, this document was revised on 9 May 2025 to include the illustrative examples developed as part of the various pieces of Administrative Guidance approved by the Inclusive Framework until March 2025.
Implementation Handbook
Published 11 October 2023
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This Implementation Handbook on the minimum tax provides an overview of the key provisions of the rules and the considerations to be taken into account by tax policy and administration officials and other stakeholders in assessing their implementation options. This handbook was prepared under the Indian Presidency of the G20 and is not intended to modify the application or interpretation of any aspect of the Model Rules, the Commentary or the Agreed Administrative Guidance.
The Global Minimum Tax Implementation Toolkit
Published 24 April 2026
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This Toolkit sets out guidelines for best‑practice and practical implementation steps to support the consistent and efficient administration of the Global Minimum Tax, drawing on the experience of jurisdictions at more advanced stages of implementation.
Funded by the European Union via the Technical Support Instrument, and implemented by the OECD, in co-operation with the European Commission. Additional financial support was provided by other contributors.
Background material
- Summary: Pillar Two Model Rules in a nutshell - Updates coming soon
- Fact sheets - Updates coming soon
- Frequently asked questions - Recently updated
- Q&As: Qualified Status under the Global Minimum Tax - Updates coming soon
Latest insights
Further information
- Contact us via e-mail: CTP.Contact@oecd.org
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