OECD developments
OECD releases fourth batch of Administrative Guidance, including new rules for allocating taxes to foreign PEs
On 17 June 2024, the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework released a fourth tranche of Administrative Guidance on the Pillar Two Global Anti-Base Erosion (GloBE) Rules. Among other items, the June 2024 Administrative Guidance provides new rules on how to allocate current and deferred taxes, including taxes that may be push…