The Administrative Guidance provides guidelines for the local implementation of the GloBE Rules, the recognition of the US’ GILTI regime and the design of the Qualified Domestic Minimum Top-up Tax.
In brief
On 2 February 2023, the OECD/G20 Inclusive Framework on BEPS (IF) released technical guidance (“Administrative Guidance“) to assist governments in the local implementation of the Global Anti-Base Erosion Model Rules (“GloBE Rules“). This should help governments to correctly apply the GloBE Rules to large Multinational Enterprises (MNE) from the start of 2024. Moreover, it aims to ensure a coordinated and harmonized implementation of the GloBE Rules. The Administrative Guidance takes the form of a modification to the original version of the Commentary that was issued in March 2022.
The IF has stated that it will continue to release additional guidance in order to ensure a harmonized and coordinated implementation of the GloBE Rules.
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