Pillar Two Elections: Jurisdictional Matrix

The OECD Model Rules include a number of elections available to MNEs to modify the treatment under the GloBE rules. 

These include the:

Excluded Entity Election 

Election to use the Realization Method 

Stock-Based Compensation Election

Election to Spread Capital Gains 

Consolidation Election

GloBE Loss Election

Tax Transparency Election 

Taxable distribution Election 

Unclaimed Accrual Election 

Distribution Tax Regime Election 

Substance-Based Income Exclusion Election

Prior Year Adjustment Election 

Transitional Safe Harbour Election 

De minimis Election

Further elections are included in the First Set of OECD Administrative Guidance and the Second Set of Administrative Guidance. These include the :

Portfolio Shareholding Election

Foreign Exchange Hedge Election

Excess Negative Tax Carry-Forward Election

Debt Release Election

Equity Investment Inclusion Election

Transitional UTPR Safe Harbour Election

QDMTT Safe Harbour Election

Not all elections have (as of yet) been included in the current draft/enacted law, particularly in relation to the elections included in the OECD Administrative Guidance. 

Our jurisdictional matrix tracks the domestic implementation of the elections in the current draft or enacted law. 

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