On March 14, 2022, the OECD launched a public consultation on the Implementation Framework. Also on March 14, 2022 the Inclusive Framework released the Commentary on the GloBE Rules, which provides MNEs and governments with detailed and comprehensive technical guidance on the operation and intended outcomes under the rules.
The next step in the work on the GloBE rules turns to the development of the Implementation Framework as agreed under the Detailed Implementation Plan set out in the October Statement. The GloBE Implementation Framework will facilitate the co-ordinated implementation and administration of the GloBE Rules. It will provide agreed administrative procedures, such as filing obligations, and multilateral review processes as well as consider the development of safe-harbours to facilitate both compliance by MNEs and administration by tax authorities.
To inform the development of the GloBE Implementation Framework, Inclusive Framework members are seeking public input on the issues that should be addressed as part of this work. This public consultation does not solicit further comment on the policy choices made in the Model Rules or the Commentary themselves. Rather the focus is on putting in place mechanisms that will ensure tax administrations and MNEs can implement and apply the GloBE Rules in a consistent and co-ordinated manner while minimising compliance costs. Questions that stakeholders may wish to address include:
· Do you see a need for further administrative guidance as part of the Implementation Framework? If so, please specify the issues that require attention and include any suggestions for the type of administrative guidance needed.
· Do you have any comments relating to filing, information collection including reporting systems and record keeping? In particular do you have any views on how the design of the information collection, filing obligations and record keeping requirements under GloBE could be designed to maximise efficiency, accuracy and verifiability of information reporting while taking into account compliance costs?
· Do you have any suggestions on measures to reduce compliance costs for MNEs including through simplifications and the use of safe-harbours?
· Do you have views on mechanisms to maximise rule co-ordination, increase tax certainty and avoid the risk of double taxation?
Deadline for comment and next steps
Persons interested in commenting on the Implementation Framework, including issues that should be addressed therein, are invited to send their written comments no later than 11 April 2022. Comments should be sent electronically (in Word format) by e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it. and may be addressed to: International Co-operation and Tax Administration Division, OECD/CTPA.
According to the OECD a public consultation meeting will be held virtually at the end of April 2022.
Copyright – internationaltaxplaza.info
and