Further tranche of Administrative Guidance on the GloBE Model Rules (Pillar Two) released

Our report summarises the highlights of the fourth tranche of administrative guidance on the Organisation for Economic Cooperation and Development’s GloBE Model Rules.

The fourth tranche of administrative guidance, released on 17 June 2024, is more than 140 pages and covers six chapters. The new material provides detailed recapture rules for deferred tax liabilities, new rules on deferred tax assets and liabilities where there are divergencies between GloBE rules and accounting carrying values, the allocation of cross-border current and deferred taxes, the allocation of profit and taxes in structures involving flow-through entities, and the treatment of se...

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Authors: Alia Lum

Published Date: 21 June 2024