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The OECD has issued final technical recommendations for the global minimum tax

The official OECD guidance on how to implement the 15% global minimum company tax rate is now available to governments.

Today, February 2, the OECD announced technical recommendations for implementing global anti-base erosion standards in order to complete pillar two this year.

The advise was signed off on by Grace Perez-Navarro, director of the OECD Centre for Tax Policy and Administration in Paris.

"While this concludes the work we had set for ourselves in October 2021, we will continue to work hard in the next months to ensure that the regulations are implemented in a coordinated and administrable manner," Perez-Navarro said.

The document, titled 'Agreed Administrative Guidance for the Pillar Two GloBE Rules,' covers topics ranging from the US minimum tax regime to the design of top-up taxes. It completes the technical guidance on pillar two when combined with guidance on safe harbours, GloBE information returns, and tax certainty issued in December 2022.

As part of the new standards, the OECD intends to consult with stakeholders on compliance costs, tax certainty, and the use of GloBE data. There will also be changes to reflect the new guidance into the March 2022 commentary.

The Inclusive Framework will continue to issue new recommendations to aid in the coordination of the GloBE regulations' implementation. Meanwhile, the OECD is putting the finishing touches on the model provision for the subject-to-tax rule.

The first pillar is the next challenge for international tax officials. The OECD expects to finalise an international treaty by mid-2023, with implementation beginning in 2024.



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