OECD Publishes Consolidated Commentary to the Global Anti-Base Erosion Model Rules and Updated Illustrative Examples

The OECD has published a Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023). The Consolidated Commentary incorporates Agreed Administrative Guidance that has been released by the Inclusive Framework since March 2022 up until December 2023. The OECD has also published updated Illustrative Examples that illustrate the application of the Model GloBE Rules to certain fact patterns. The updates include illustrative examples that were developed as part of the various piece…