On March 14, 2022, the Inclusive Framework on BEPS released Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two) (224 pages). Furthermore the OECD also released illustrative examples regarding the application of the Model GloBE Rules to certain fact patterns (44 pages).

Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two)

The Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two) provides commentary to the Globe Rules where it follows the article by article approach.

The Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two) as released by the Inclusive Framework on March 14, 2022 can be found here.

Global Anti-Base Erosion Model Rules (Pillar Two) Examples

The second document containing illustrative examples regarding the application of the Model GloBE Rules to certain fact patterns at a first glance looks very helpful and very interesting. The illustrative examples are ordered by the article they relate to and that make it very efficient to have a look and find the illustrative examples that regard the article you are struggling with.

The Global Anti-Base Erosion Model Rules (Pillar Two) Examples can be found here.

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