The OECD/G20 Inclusive Framework on BEPS (IF) published the fourth set of Administrative Guidance (the guidance) on the Global Anti-Base Erosion Model Rules (GloBE rules) of Pillar Two on 17 June 2024, intending to clarify the operation of the GloBE rules. The guidance will be incorporated into the Commentary to the GloBE rules, which was updated in April 2024 to reflect the previous sets of Administrative Guidance. While elements of the guidance are undoubtedly helpful, in many cases that is vitiated by a corresponding increase in complexity.
Two separate Pillar Two FAQ documents accompanied the guidance - one general FAQ covering a range of topics, and another focused on the peer review mechanisms for determining the qualification status of countries’ GloBE rules.
Also on 17 June, the OECD released supplementary guidance on Amount B of Pillar One (the supplementary guidance) that includes definitions of ‘qualifying jurisdictions’ to apply the operating expense cross-check and data-availability mechanism. The supplementary guidance also includes a list of ‘Covered Jurisdictions’ (previously referred to as ‘Low-Capacity Jurisdictions’) within scope of the political commitment on Amount B.
International Tax and Treasury