OECD Publishes The Pillar Two Model Rules On The Implementation Of 15% Global Minimum Tax

On the 20^th December 2021, the Organisation for Economic Co-operation and Development (the "OECD") issued a press release and published the Global Anti-Base Erosion Model Rules (Pillar Two)  (the "Rules") in relation to the domestic implementation of a 15% global minimum corporate tax rate. This aim is to mitigate a number of tax challenges which come to light as a result of the digitalisation and globalisation of the economy.

The Rules contribute towards a harmonised structure of taxation aimed at ensuring that multinational enterprise ("MNE") groups having a revenue of more than Euro 750 million, pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. This is done by implementing a top-up tax on profits arising in a jurisdiction whenever the effective tax rate is lower than the minimum 15% rate.