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ARTICLE · 25 OCTOBER 2023

Tax Update - August

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On 13 July, the OECD published a second set of Administrative GuidanceOpens in new window on the GloBE rules (the "Updated Guidance"). The Updated Guidance includes details...

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OECD Administrative Guidance on Pillar 2

On 13 July, the OECD published a second set of Administrative Guidance on the GloBE rules (the "Updated Guidance"). The Updated Guidance includes details on currency conversion when performing GloBE calculations, on tax credits, and on the application of the Substance-based Income Exclusion ("SBIE"). It also contains further guidance on the design of the Qualified Domestic Minimum Top-up Taxes ("QDMTT") as well as two new safe harbours, as follows:

  • A permanent safe harbour for jurisdictions that introduce a QDMTT, which will make compliance and administration easier for Multinational Enterprise Groups ("MNEs") and tax administrations.

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