Update on Pillar 2 following Commentary Release – March 2022

On 14 March 2022, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) involving more than 140 countries, released Commentary related to the Model GloBE Rules under Pillar 2, which were first released on 20 December 2021. In addition to the March Commentary of 228 pages, a document containing 24 Examples and 49 pages was released to supplement the Commentary.

The Model, Commentary and Examples provide the framework for a Global Minimum Tax at 15% for Multi-national Enterprises with a turnover of more than €750 million.

Alongside the release of the Commentary, the OECD opened a public consultation on the administrative and compliance aspects of the GloBE Rules, including the potential terms of any simplifications and the use of Safe Harbors.  Written comments are due no later than 11 April 2022.  A follow-on public consultation meeting is scheduled for the end of April 2022.

The KPMG global release on updated analysis on Pillar 2, top 20 questions and answers on new GloBE Model Rules commentary, as well as the earlier KPMG Tax Whiz, can be accessed via the above links.