Jurisdictions that choose to implement the Pillar Two GloBE Rules will need to enact domestic legislation to give effect to the rules. This raises the possibility that there could be differences in the interpretation or application of the rules between different jurisdictions.
This would create uncertainty for MNE Groups and could potentially result in double taxation from the application of the GloBE rules in different jurisdictions.
The OECD is therefore seeking feedback on proposed measures to provide tax certainty for MNEs. The proposals are broadly split between dispute prevention measures and dispute resolution measures.
This is to be achieved through a multilateral review process.
Referral to the Inclusive Framework on BEPS
Where there is uncertainty in the interpretation or application of the GloBE Rules between jurisdictions, relevant jurisdictions can refer an issue to the Inclusive Framework on BEPS for clarification.
Note that this does not apply to an issue concerning taxation in a specific case and taxpayer information could not be shared.
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Lee is a qualified Chartered Accountant and Chartered Tax Adviser.
A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in
Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.
Lee's books have been recommended by The Times, The Guardian and The Telegraph.
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