OECD: Administrative guidance for implementation of Pillar Two global minimum tax rules

Pillar Two global anti-base erosion (GloBE) rules

Administrative guidance for implementation

The Organisation for Economic Cooperation and Development (OECD) today released Agreed Administrative Guidance for the Pillar Two GloBE Rules [PDF 1.6 MB]—as part of the ongoing work of the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) in implementing the two-pillar solution to address the tax challenges arising from the digitalisation of the economy.

As explained by today’s OECD release,

  • The guidance will ensure coordinated outcomes and greater certainty for businesses as they move to apply the global minimum corporate tax rules from the beginning of 2024. The document includes:
    • Guidance on the recognition of global intangible low-taxed income (GILTI) under the global anti-base erosion (GloBE) rules and on the design of qualified domestic minimum top-up taxes
    • More general guidance on the scope, operation and transitional elements of the GloBE rules to allow Inclusive Framework (IF) members that are in the process of implementing the rules to reflect this guidance in their domestic legislation in a coordinated manner
    • Responses to stakeholder feedback on technical issues, such as the collection of top-up tax in a jurisdiction in a period where the jurisdiction has no GloBE income, and the treatment of debt releases and certain tax credit equity structures
  • Together with the December 2022 publication of the guidance on safe harbours and penalty relief [PDF 414 KB], as well as the public consultation document on the GloBE information return [PDF 1.1 MB] and public consultation document on tax certainty for the GloBE rules [PDF 329 KB], the guidance finalizes the implementation framework as set out in the October 2021 Statement on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy.

Next steps

  • The guidance will be incorporated into a revised version of commentary that will be released later this year and replace the original version of the Commentary issued in March 2022.
  • The IF will continue to release further agreed administrative guidance, to ensure that the GloBE rules continue to be implemented and applied in a coordinated manner.
  • The IF expects to finalize the model provision for the subject to tax rule and the related multilateral instrument to assist in its implementation.
  • Under Pillar One, technical work is still ongoing with the aim to finalize a new multilateral convention by mid-2023, for entry into force in 2024.


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