OECD/IF Releases Administrative Guidance On The GloBE Rules

On 15 January 2025, the OECD / Inclusive Framework (IF) released additional Administrative Guidance (Jan 2025 AG) and related documents on the Pillar Two global minimum taxation rules (GloBE Rules):

• Limitation on use of deferred tax assets (DTAs). Guidance on the application of the transitional rules, notably the treatment of certain deferred tax assets that arose prior to the application of the GloBE Rules as a result of governmental arrangements, retroactive elections, or following the introduction of a new corporate income tax;
• Central Record of transitional qualified status jurisdictions. The Central Record of Legislation with Transitional Qualified Status (Central Record), listing jurisdictions whose minimum tax legislation obtained transitional qualified status (Transitional Qualified Status) and a related updated Q&A;