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International review for February 2023

The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).

Administrative guidance for implementation of Pillar Two

As part of the Inclusive Framework’s (IF) ongoing work to implement Pillar Two administrative guidance (AG) on the global anti-base erosion (GloBE) rules was released on 2 February 2023. The AG adds to the expanding body of guidance – exceeding 450 pages – that has been approved by the IF on the GloBE rules.

The AG consists of 111 pages covering 26 items which aim to clarify and in some instances simplify the application of the GloBE rules. The items cover five categories: scope income & taxes application of GloBE rules to insurance companies transition and qualified domestic minimum top-up taxes (QDMTTs).

A detailed analysis of the AG is outside the scope of this article...

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