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The OECD has released additional technical guidance on the 15% global minimum tax agreed in October 2021 as part of the Two-Pillar solution to address the tax challenges arising from digitalisation of the economy. The model rules on Pillar Two were published in December 2021.
OECD releases Pillar Two model rules
Pillar Two consists of two rules intended for introduction in national domestic tax laws -together known as the Global anti-Base Erosion (GloBE) rules -as well as a treaty-based rule. The technical advice issued today is composed of a commentary to the GloBE rules, which includes clarification of certain terms to ensure consistent interpretation, and examples illustrating the rules.
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