OECD issues new guidance on GloBE Rules

A second set of very detailed administrative guidance on Pillar Two (the first set was published in February 2023) covers the following:

• currency conversion rules when performing GloBE calculations;
• the treatment of tax credits under the GloBE Rules;
• application of the substance-based income exclusion (SBIE);
• design of qualified domestic minimum top-up taxes (QDMTT); and
• permanent safe harbour for jurisdictions which introduce a QDMTT, and a transitional UTPR (under-taxed profits rule) safe harbour.

The OECD has also published a useful Pillar Two rules in a nutshell summary guide.