The OECD has released Global Anti-Base Erosion Model Rules (Pillar Two) on their website on 20 December, 2021.
These Model Rules form part of BEPS 2.0 Project and provide governments with a template for implementing the Pillar 2 agreement that was reached in October 2021 by 137 jurisdictions in the OECD/G20 BEPS Inclusive Framework.
The Global Anti-Base Erosion Rules (GloBE) are a key component of this plan and ensure large multinational enterprise pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.
The Pillar Two:
defines the scope of the GloBE Rules;
determines the constituent entities in the group that are liable for any top-up tax and the portion of any top-up tax charged to any such entity;
contains rules relating to acquisitions, disposals and joint ventures;
covers administrative aspects of the GloBE Rules including information filing requirements as well as the application of any safe-harbours.