OECD: Further administrative guidance on Pillar Two rules; statement on timeline of Pillar One multilateral convention

Further administrative guidance to assist governments

Statement on timeline of Pillar One multilateral convention

The Organisation for Economic Cooperation and Development (OECD) today released further administrative guidance to assist governments with implementation of the global minimum tax under Pillar Two and a statement on the timeline of the multilateral convention (MLC) under Pillar One.

As explained by today’s OECD release:

  • The Agreed Administrative Guidance for the Pillar Two GloBE Rules (December 2023) [PDF 478 KB] released today supplements the commentary to the global anti-base erosion (GloBE) model rules in order to clarify their application, including guidance on the application of the transitional country-by-country (CbC) reporting safe harbor and a mechanism for allocating taxes arising in a blended controlled foreign corporation (CFC) tax regime when some of the jurisdictions a multinational enterprise (MNE) operates in are eligible for the safe harbor. The Inclusive Framework also indicated that it will:
    • Continue to release further agreed administrative guidance on an ongoing basis to respond to stakeholder requests for clarification of various aspects of the GloBE rules and, when necessary, address aggressive tax planning that may undermine the integrity of the rules or their application to certain MNE groups
    • Continue to develop simplifications on key compliance items on a timely basis, including guidance expected in the first half of 2024 on the application of deferred tax liability recapture rules and the allocation of deferred taxes relating to cross-border taxes such as CFC tax regimes
    • Implement a robust and transparent peer review process and continue the ongoing work on the administrative framework and dispute resolution mechanisms with a view to providing a high level of tax certainty to stakeholders in applying the rules
  • The statement [PDF 92 KB] updating the timeline to finalize the text of the Pillar One MLC expresses the continued and strong commitment of Inclusive Framework delegates to resolve the outstanding issues, achieve a consensus-based solution and finalize the text of the MLC as swiftly as possible.



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