The OECD/G20 published on 20 December 2022 a set of rules for the application of the Global Rules to Combat Base Erosion (GloBE Rules), as part of the set of amendments introduced by Pillar Two. The set of documents provides a coordinated system to ensure the implementation of an effective minimum 15% tax on profits incurred in each jurisdiction by multinational enterprises with global revenues above EUR 750 million. The documentation also includes a set of transitional provisions designed to ease the administrative burden on multinational groups in the first years of application of the new rules.
Work on the subject to tax rule and the implementation of the multilateral instrument is under preparation and is expected to be published during 2023.
Source: Pillar Two implementation package, published by OECD on 20 December 2022
