Key Differences in Excluded Entities Between The OECD Model Rules & UK Draft Legislation

  1. Definition of Excluded Entity – Article 1.5.1 of the OECD Model Rules
  2. Extension to 85% Subsidiary Requirement – Article 1.5.2(b) of the OECD Model Rules
  3. Excluded Entity Election – Article 1.5.3 of the OECD Model Rules
  4. Excluded Entities and Permanent Establishments

The Spring Finance Bill 2023 (Finance (No. 2) Bill) was published on March 23, 2023, along with its Explanatory Notes.  The Bill includes provisions to implement key aspects of the Pillar Two Global Minimum Tax for accounting periods beginning on or after 31 December 2023.

Whilst individual jurisdictions implementing the GloBE rules are required to be consistent with the OECD Model rules to ensure uniform application, it is inevitable that there will be jurisdictional differences.

In this article we highlight key differences between the UK approach to Excluded Entities in the draft GloBE legislation and the approach taken in the OECD Model Rules.

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