OECD: Inclusive Framework on BEPS releases updates to global minimum tax administration

The Organisation for Economic Cooperation and Development (OECD) today announced additional administrative guidance under the Pillar Two rules, including several developments aimed at streamlining the administration of the global minimum tax.

According to today’s OECD announcement, key releases include:

• Central record of legislation with transitional qualified status: This document lists jurisdictions whose minimum tax legislation has completed the fast-track process and secured transitional qualified status. It will be updated regularly to include additional jurisdictions.
• Administrative guidance on Article 9.1 of the GloBE model rules: This guidance excludes certain deferred tax assets from the computation of an MNE group’s effective tax rate when they arose before the global minimum tax application due to specific governmental arrangements or the introduction of a new corporate income tax. Jurisdictions may need to amend domestic legislation to apply aspects of this guidance.
• Updated GloBE information return (GIR): The updated GIR, initially released in July 2023, includes simplifications and clarifications based on stakeholder feedback. It also features a new annex with an optional notification template for jurisdictions requiring notification from MNE groups about receiving the GIR through information exchange.
• GIR multilateral competent authority agreement (MCAA) and related tools: The GIR MCAA outlines conditions for the automatic exchange of GIR information under the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The GIR XML Schema and User Guide provide a common electronic format for the GIR, with further work planned on validation rules to ensure data consistency and quality before filing and exchange.

The OECD today also released guidance on the qualified status under the global minimum tax in “question and answer” (Q&A) format.