OECD Updates Consolidated Commentary to the Global Anti-Base Erosion Model Rules

The OECD has published an updated Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2026). The Consolidated Commentary incorporates administrative guidance that has been released by the Inclusive Framework from March 2022 to January 2026. Click the following link for the OECD Global Anti-Base Erosion Model Rules (Pillar Two) page for more information, including past versions of the consolidated commentary.

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Abstract

Addressing the tax challenges arising from the di…