OECD Issues the Agreed Administrative Guidance for the GloBE Rules

Today the OECD has issued the Agreed Administrative Guidance for the Pillar Two GloBE Rules. This is the final part of the implementation framework for the GloBE Rules. 
Running to 111 pages, it provides guidance on some of the outstanding issues that were left open in the Commentary issued in March 2022. 
It’s broken down into five main sections:
In this article, we look at some of the key highlights of the OECD Administrative Guidance, including:
  • Substitute loss-carry forwards;
  • GILTI treatment;
  • QDMTT design;
  • Excluded dividends and mismatches;
  • Debt releases;
  • Deemed distributions;
  • Transitional deferred tax rules;
  • Tax credit carry-forwards (QRTCs and non-QRTCs); and the 
  • Transitional asset transfer rules.
Also see our Pillar Two Navigator for updated analysis including:
Substitute Loss Carry-Forwards

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