International review for January 2025

OECD: further Pillar Two releases

On 15 January 2025 the OECD Inclusive Framework (IF) on BEPS released a series of documents on the application of the Global Anti-Base Erosion (GloBE) rules. The primary focus is compliance and reporting obligations although there is also some limited Administrative Guidance (AG) that amends certain aspects of the GloBE Model Rules. A full analysis of the documents is beyond the scope of this article but in summary include:

• Updated GloBE information return (GIR): The publication confirms that as a general principle the GIR will be completed based on the GloBE Model Rules and Commentary (as amended by any AG). This is designed to ensure that the GIR is completed using a single data source and the clarification addresses an area of uncertainty. However...