OECD/G20 Inclusive Framework releases additional Administrative Guidance on Pillar Two GloBE Rules: Detailed review
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On 17 July 2023, the Organisation for Economic Co-operation and Development (OECD) released Administrative Guidance on the Pillar Two Global Anti-Base Erosion (GloBE) Rules.
The July Guidance covers technical issues relating to currency conversion, tax credits, the Substance-based Income Exclusion and the Qualified Domestic Minimum Top-up Tax and provides two new safe harbors.
Companies should evaluate the new information in the July Guidance that is relevant to the operation of the GloBE Rules in…
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