The OECD/G20 Inclusive Framework on BEPS has released Commentary 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 Commentary elaborates on the application and operation of the Global Anti-Base Erosion (GloBE) Rules agreed and released in December 2021.
The Commentary provides MNEs and tax administrations with detailed and comprehensive technical guidance on the operation and intended outcomes under the rules and clarifies the meaning of certain terms. It also illustrates the application of the rules to various fact patterns. The Commentary is intended to promote a consistent and common interpretation of the GloBE Rules that will facilitate co-ordinated outcomes for both tax administrations and MNE Groups.