KPMG report: New administrative guidance on Pillar Two rules, initial observations and analysis

A KPMG report providing initial observations and analysis of new administrative guidance

A KPMG report providing initial observations and analysis of new administrative guidance

The Organisation for Economic Cooperation and Development (OECD) on 18 December 2023 released its third tranche of administrative guidance on the global anti-base erosion (GloBE) model rules to assist governments with implementation of the global minimum tax under Pillar Two. Read TaxNewsFlash

The guidance is principally focused on the application of the transitional country-by-country reporting (CbCR) safe harbor, which was introduced in guidance released in December 2022 and enables a multinational enterprise group to avoid both completing a full GloBE computation and paying a top-up tax for jurisdictions when they are eligible for one of three safe harbor tests: (1) de minimis; (2) simplified effective tax rate (ETR); and (3) routine profits.

Read a December 2023 report [PDF 645 KB] prepared by KPMG LLP that provides initial observations and analysis of the new administrative guidance. 


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