Base erosion and profit shifting

Tax challenges of digitalisation: OECD invites comments on compliance and tax certainty aspects of global minimum tax


20/12/2022 - As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on compliance and co-ordination aspects of the Pillar Two global minimum tax.



In October 2021, the international community reached a landmark agreement on a two-pillar solution to reform the international tax rules to address the tax challenges arising from globalisation and digitalisation.


Last December, the Inclusive Framework published the Model Global Anti-Base Erosion (GloBE) Rules. Once implemented into domestic law, the GloBE Rules will provide a co-ordinated system to ensure that Multinational Enterprises (MNEs) with revenues above EUR 750 million pay at least a minimum level of tax – at an effective rate of 15% – on the income arising in each of the jurisdictions in which they operate.


In March 2022, the Inclusive Framework released the Commentary on the GloBE Rules, which provides MNEs and governments with detailed and comprehensive technical guidance on the operation and intended outcomes under the rules.


Following the subsequent public consultation on the Implementation Framework of the global minimum tax, the Inclusive Framework has worked on issues related to administration, operation, compliance and rule co-ordination and is now seeking public input on compliance and co-ordination aspects of the Pillar Two GloBE Rules.


Public consultation

Two documents are released for public consultation:

  • The public consultation document on the GloBE Information Return seeks input on the amount and type of information that MNE Groups should be expected to collect, retain and/or report for the application of the GloBE Rules and possible simplifications that could be incorporated in the GloBE Information Return as well as the ability of the MNE Group to provide alternative data points.
  • The public consultation document on Tax Certainty for the GloBE Rules outlines various mechanisms, including dispute prevention and dispute resolution, for achieving tax certainty under the GloBE Rules. The document outlines the expected next steps in connection with the development of these mechanisms and identifies a number of areas where stakeholder input would be valuable.


The comments provided will assist members of the Inclusive Framework in completing the work relating to compliance and co-ordination aspects of the Pillar Two GloBE Rules to preserve consistent and co-ordinated outcomes for MNEs while minimising compliance burdens and avoiding the risk of double taxation.


Interested parties are invited to send their comments* on each of these documents no later than Friday, 3 February 2023. Instructions for submitting comments can be found in each document.


Further information on the two-pillar solution for addressing the tax challenges arising from digitalisation and globalisation of the economy is available at


For further information or inquiries, please contact [email protected].


*Please note that all written comments received will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.