Model GloBE Rules | Commentary | Examples
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. 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 minimum rate.
![]() |
Published 20 December 2021
|
This report 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.
![]() |
Published 14 March 2022 Download the report (PDF)
|
This Commentary explains the intended outcomes under the GloBE Rules and clarifies the meaning of certain terms. It also illustrates the application of the rules to certain fact patterns.
![]() |
Published 14 March 2022 Download the report (PDF)
|
These examples illustrate the application of the Model GloBE Rules to certain fact patterns.
Background material
Press releases
More information
Related Documents