Large multinationals (MNEs) may want to review the Organization for Economic Cooperation and Development’s (OECD) new administrative guidance on Pillar Two’s “global anti-base erosion” (GloBE) rules. This new guidance, which was issued on December 18, 2023, clarifies the application of certain rules, including the transitional country-by-country reporting (CbCR) safe harbour, among others. This guidance is intended to help Canada and other jurisdictions to implement the GloBE rules in their domestic legislation as part of its two-pillar solution to address the tax challenges from digitalization of the economy. Note that these rules affect not only MNEs headquartered in Canada, but also Canadian entities of foreign-based MNEs.

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