This factsheet highlights the main provisions in the OECD’s Pillar Two GloBE proposals. The European Union’s (EU) Directive to implement these could considerably impact some very large businesses.

The number of affected businesses should remain limited but the Directive is long and complex. Those businesses and their advisors should therefore begin risk analysis as soon as possible.

Introduction

The EU Pillar 2 Directive codifies into EU law additional anti-BEPS measures developed in parallel with the OECD’s work on re-distributing the tax base for certain Multi-National Entities (MNEs).
The Directive is now effective and was published in the Official Journal on 22 December 2022.
This factsheet summarises the Directive’s main points. The Global Anti-Base Erosion Model Rules (GloBE) provisions are complex and extensive. Businesses likely to fall within the scope of GloBE should consult the full rules and seek independent advice, if appropriate.
The income inclusion rule will be effective from 31 December 2023. The undertaxed profits rule will be effective from 31 December 2024....

 more in full paper