New guidance on Pillar Two GloBE Rules

The Inclusive Framework has published Agreed administrative guidance for the Pillar Two GloBE rules. The new guidance addresses various issues identified by Inclusive Framework members as most in need of immediate clarification and simplification.

The document includes guidance on the recognition of the US minimum tax under the GloBE Rules and on the design of qualified domestic minimum top-up taxes.

The guidance also responds to stakeholder feedback on technical issues, including the collection of top-up tax in a jurisdiction in a period where the jurisdiction has no GloBE income, and the treatment of debt releases and certain tax credit equity structures.

The guidance is to be incorporated into a revised version of the Inclusive Framework’s commentary Tax challenges arising from the digitalisation of the economy – commentary to the Global Anti-Base Erosion Model Rules (Pillar Two).