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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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Mounia Benabdallah is a principal in Baker McKenzie’s International Tax Practice Group. She joined Baker McKenzie in 2006 and has practiced in the Firm’s offices in Amsterdam, Chicago and New York. As an attorney at law she is admitted to the Netherlands Bar. Mounia is repeatedly recognized as leading advisor in ITR’s Women in Tax Leaders guide. Because of her strong US focus, Mounia is based in New York and member of the Global Reorganizations Practice Group. Mounia mainly advises US multinationals on the interplay between US international tax law, European tax law and Netherlands tax law in global restructuring projects, with a strong focus on global (OECD BEPS) and European tax policy developments.


Narine Movsisian is a senior associate in Baker McKenzie's Tax Practice Group.


Ed Swift is a Senior Associate in Baker McKenzie London office.


Pablo Fernandez is an Associate in baker McKenzie, Barcelona office.

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