Base erosion and profit shifting

Tax challenges of digitalisation: OECD invites public input on the Implementation Framework of the global minimum tax


14/03/2022 -


Completion of technical work on GloBE Rules and Commentary

Last December, the OECD/G20 Inclusive Framework on BEPS published the Global Anti-Base Erosion (GloBE) Rules as part of a landmark agreement on a two-pillar solution to reform the international tax framework in response to the challenges of digitalisation of the economy. 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 15% – on the income arising in each of the jurisdictions in which they operate.


Today 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.
The next step in the work on the GloBE rules turns to the development of the Implementation Framework as agreed under the Detailed Implementation Plan set out in the October Statement. The GloBE Implementation Framework will facilitate the co-ordinated implementation and administration of the GloBE Rules. It will provide agreed administrative procedures, such as filing obligations, and multilateral review processes as well as consider the development of safe-harbours to facilitate both compliance by MNEs and administration by tax authorities.


Public consultation on the Implementation Framework

To inform the development of the GloBE Implementation Framework, Inclusive Framework members are seeking public input on the issues that should be addressed as part of this work. This public consultation does not solicit further comment on the policy choices made in the Model Rules or the Commentary themselves. Rather the focus is on putting in place mechanisms that will ensure tax administrations and MNEs can implement and apply the GloBE Rules in a consistent and co-ordinated manner while minimising compliance costs. Questions that stakeholders may wish to address include:

  • Do you see a need for further administrative guidance as part of the Implementation Framework? If so, please specify the issues that require attention and include any suggestions for the type of administrative guidance needed.
  • Do you have any comments relating to filing, information collection including reporting systems and record keeping? In particular do you have any views on how the design of the information collection, filing obligations and record keeping requirements under GloBE could be designed to maximise efficiency, accuracy and verifiability of information reporting while taking into account compliance costs?
  • Do you have any suggestions on measures to reduce compliance costs for MNEs including through simplifications and the use of safe-harbours?
  • Do you have views on mechanisms to maximise rule co-ordination, increase tax certainty and avoid the risk of double taxation?


Stakeholder input on issues of administration, operation, compliance and rule co-ordination will be critical in identifying the Inclusive Framework’s priorities in developing the GloBE Implementation Framework that is efficient for taxpayers and tax administrations and preserve consistent and co-ordinated outcomes for MNE’s that avoid the risk of double taxation.


Deadline for comment and next steps

Persons interested in commenting on the Implementation Framework, including issues that should be addressed therein, are invited to send their written comments no later than 11 April 2022. Comments should be sent electronically (in Word format) by e-mail to [email protected] and may be addressed to: International Co-operation and Tax Administration Division, OECD/CTPA.

A public consultation meeting will be held virtually 25 April 2022, to register visit the event page.

Please note that all written comments received will be made publicly available on the OECD website. 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.


Enquiries should be directed to Achim Pross (+33 1 45 24 98 92), Head of International Co-operation and Tax Administration Division at the OECD Centre for Tax Policy and Administration (CTPA) or to John Peterson (+33 1 45 24 74 41), Head of CTPA’s Aggressive Tax Planning Unit or to [email protected].