Base erosion and profit shifting

Minimum Tax Implementation Handbook (Pillar Two)


Published 11 October 2023


Download the report


A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation and globalisation of the economy. The global minimum tax, together with the Subject to Tax Rule, constitutes the second pillar of the Two-Pillar Solution developed to address those challenges. The minimum tax will ensure large multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. The minimum tax is based on an agreed set of Model Rules, that are designed to be implemented into domestic law as part of a common approach. 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 Implementation 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.


Press release


Further information


Related Documents