OECD / Inclusive Framework

• GloBE model rules (December 20, 2021)

• Consolidated Commentary on GloBE rules (2023) (April 25, 2024)

• Examples (updated) (April 25, 2024)

• February 2023 Administrative Guidance on GloBE rules (February 2, 2023)

• July 2023 Administrative Guidance on GloBE rules (July 17, 2023)

• December 2023 Administrative Guidance on GloBE rules (December 18, 2023)

• June 2024 Administrative Guidance on GloBE rules (June 17, 2024)

• January 2025 Administrative Guidance on Article 8.1.4 and 8.1.5 of GloBE rules (January 15, 2025)

• January 2025 Administrative Guidance on Article 9.1 of GloBE rules (January 15, 2025)

• Central Record of Legislation with Transitional Qualified Status (January 15, 2025)

• Qualified Status under the Global Minimum Tax – Questions and Answers (January 15, 2025)

• GloBE Information Return (updated) (January 15, 2025)

• GloBE Information Return XML Schema – User Guide for Tax Administrations (January 15, 2025)

• Multilateral Competent Authority Agreement on the Exchange of GloBE Information (January 15, 2025)

• Safe Harbours and Penalty Relief (December 20, 2022)

• Tax Certainty for GloBE rules (public consultation document) (December 20, 2022)

• Background material:

  • Pillar Two rules in a nutshell (updated July 2023)

  • Fact sheets

  • Frequently asked questions

• Statement on Two-Pillar Solution (Inclusive Framework) (October 8, 2021)

• Pillar Two Blueprint (October 14, 2020)

• OECD: GloBE homepage

• OECD: BEPS homepage

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Note: for material on the Subject-to-Tax Rule (STTR), please refer to the "Treaties" page.

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EU

• Council Directive (EU) 2022/2523

• European Commission: Minimum corporate taxation homepage

• Frequently Asked Questions on the Pillar 2 Directive (December 22, 2023)

• Commission Notice – Election to delay application of the IIR and UTPR under Article 50 of the Pillar Two Directive (December 12, 2023)

• Council and Commission Statements on the two-pillar solution (November 9, 2023)

• Consent letter of 23 October 2023 from Cyprus authorities on the qualifying international agreements referred to under Art. 32 (October 23, 2023)

• Consent letter of 22 March 2023 from Cyprus authorities on the qualifying international agreements referred to under Art. 32 (March 22, 2023)