OECD/IF Releases Further Administrative Guidance On The GloBE Rules (Pillar Two)

On 18 December 2023, the OECD released further Administrative Guidance on the global minimum taxation rules (GloBE Rules, which form part of Pillar Two). The new Administrative Guidance notably contains further guidance on the application of the Transitional CbCR Safe Harbour, the EUR 750m revenue threshold, the allocation of Blended CFC Taxes such as GILTI, and a Simplified Calculation Safe Harbour for entities excluded from the consolidated financial statements based on size or materiality grounds.

Below we outline the main items of this further administrative guidance (Dec 2023 AG), which is the third set of additional administrative guidance after the guidance released in February 2023 (Feb 2023 AG) and July 2023 (July 2023 AG).