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.
Two documents are released for public consultation:
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 https://oe.cd/bepsaction1.
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.