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On December 17, 2021 the OECD released the Global Anti-Base Erosion (GloBE) Model Rules under Pillar Two. The GloBE Model Rules do not directly/automatically apply to multinational enterprises (MNEs), but they have to be implemented by local jurisdictions in order for the rules to apply to MNEs. For the EU this will be done via a two-step implementation process. Step one is an EU Directive, which obliges the EU Member States to implement the (minimum) regulations laid down in a Directive. The second step is then that the EU Member States will have to transpose the regulations laid down in the Directive into their national domestic tax laws.
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On March 14, 2022, the OECD released Commentary to the Global Anti-Base Erosion (GloBE) (Pillar 2) Model Rules. Furthermore also a set of illustrative examples regarding the application of the Model GloBE Rules to certain fact patterns was released.
As you might know on December 22, 2021 the European Commission released a Proposal for a Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union.
Read more: A correlation table for the EU Pillar 2 Directive and the OECD Model Rules
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Last week I finally took the time to study and digest the Pillar Two model rules that the OECD released on December 20, 2021 and the thereupon based proposal of the European Commission for an EU Council Directive on ensuring a global minimum level of taxation for multinational groups in the Union that was published on December 22, 2021. And what I envisioned to take a day, quickly turned out to take much longer than I expected.
This article basically functions as the introduction to a set of 9 seperate articles which provide information to each of the 9 steps identified below. Links to each of these nine articles you can find at the bottom of this article.
