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The OECD/G20 Inclusive Framework on BEPS (IF) published a range of documents relating to the Two-Pillar solution on 17 July 2023, one of which was a second set of Administrative Guidance on the Pillar Two GloBE Model Rules . This release follows the publication of the first set of Administrative Guidance in February 2023. The guidance covers a range of issues where stakeholders sought additional clarity, including general currency conversion standards for the GloBE Rules, guidance on tax credits, the Substance Based Income Exclusion (SBIE), Qualified Domestic Minimum Top-up Tax (QDMTT) and safe harbours. The guidance, including more detailed examples, will be incorporated into a revised version of the Commentary that will be released later this year. Also released as part of the OECD package was an updated version of the GloBE Information Return (GIR). 

The guidance brings greater clarity on matters including transferable credits, the provision of two new safe harbours and the application of the QDMTT to entities (other than constituent entities of an MNE Group. However, questions remain in terms of the benefits of some of the transitional reliefs, other unresolved transition issues, the practical application of the currency conversion rules, and of course whether countries will incorporate this latest guidance into their local GloBE rules implementation.