Base erosion and profit shifting

Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two)


Model GloBE Rules | Commentary | Administrative GuidanceSafe Harbours and Penalty ReliefExamples | Background material


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.


Model GloBE Rules

image of Tax Challenges Arising from Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two)

Published 20 December 2021


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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.


Commentary to the GloBE Rules - first edition

image of Tax Challenges Arising from the Digitalisation of the Economy – Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two), First Edition

Published 14 March 2022


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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.


Agreed Administrative Guidance for the Pillar Two GloBE Rules


Published 2 February 2023


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The Agreed Administrative Guidance will ensure co-ordinated outcomes and greater certainty for businesses as they move to apply the global minimum corporate tax rules from the beginning of 2024. The Agreed Administrative Guidance will be incorporated into a revised version of the Commentary that will be released later in 2023 and replace the original version of the Commentary issued in March 2022. The Inclusive Framework will continue to release further Agreed Administrative Guidance on an ongoing basis, to ensure that the GloBE Rules continue to be implemented and applied in a co-ordinated manner.


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 14 March 2022


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These examples illustrate the application of the Model GloBE Rules to certain fact patterns.


Background material


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