OECD Guidance and Updates on Pillars Lays Bare Their Complexity

On June 17, 2024, the OECD released several pieces of new guidance relating to the development and implementation of Pillar 2 and Pillar 1. This article briefly highlights the key elements of the categories of guidance identified by the OECD to which the authors recommend multinational enterprises (MNEs) and their advisors give focused scrutiny.

The most notable items in the guidance include:

1. A fourth set of Administrative Guidance (AG) with respect to the application and interpretation of the Globe Model Rules (“GloBE Rules”) (OECD, Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the ...