ARTICLE · 09 FEBRUARY 2024

Minimum Tax Implementation Handbook (Pillar Two) – Pillar II In Plain English

SNG Grant Thornton

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A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation and globalisation of the economy.

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Raeesa Haneef-Danka

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation and globalisation of the economy. The global minimum tax, together with the Subject to Tax Rule, constitutes the second pillar of the Two-Pillar Solution developed to address those challenges.

The minimum tax will ensure large multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. The minimum tax is based on an agreed set of Model Rules, that are designed to be implemented into domestic law as part of a common approach.

Recently, the OECD has released a 31-page document that explains the main concepts of the Pillar 2 rules in plain English. The purpose of the Implementation Handbook is to supplement the Global Anti-Base Erosion (GloBE) rules. It is not intended as additional detailed guidance material but rather seeks to present the core elements of the rules in a manner that provides a

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