Pillar Two and the GloBE rules

We are only months away from the implementation of a minimum rate of corporation tax across much of the world – a feat that many thought impossible, and which would have been unthinkable until relatively recently. What will the changes mean and why are we pursuing them? What are the logistics of achieving such fundamental changes to the international tax landscape? This guide considers the rules implementing the OECD’s Pillar Two proposals, including consideration of the concepts of effective tax rate, the income inclusion rule, the undertaxed payments rule and the subject-to-tax rule, as well as highlighting some of the aspects that are likely to raise issues.