OECD
Model Rules on the Pillar Two Global Minimum Tax
On 20 December 2021, the Organisation for Economic Co-operation and Development (OECD) released the Pillar Two Model Rules as part of the two-pillar solution to address the tax challenges arising from the digitalization of the economy.
Pillar Two includes two interlocking rules that together comprise the Global Anti-Base Erosion (GloBE) rules: (i) the Income Inclusion Rule; and (ii) the Undertaxed Payment Rule. According to the Model Rules…