​The Organization for Economic Cooperation and Development (OECD) has now published almost 300 pages of commentary and examples on its model global minimum tax rules released in December 2021. This new commentary, which was issued on March 14, 2022 provides technical guidance on these rules, which are intended to help Canada and other jurisdictions to implement changes as part of its two-pillar solution to address the tax challenges from digitalization and globalization of the economy. The OECD also announced that it will accept comments on the implementation framework for the global minimum tax rules until April 11, 2022.

As these rules are intended to be effective starting in 2023, multinational enterprises (MNEs) should prepare for these upcoming changes by continuing to monitor developments and the timing of legislative proposals in different jurisdictions. In addition, affected MNEs should model the potential impacts of these complex changes and evaluate conflicts with existing domestic rules to prevent double taxation or other inadvertent issues.

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