The OECD has published model rules to give effect to its Global Anti-Base Erosion (GLoBE) regime requiring large multinational enterprises to pay a 15 per cent minimum tax rate on income arising in each of the jurisdictions where they operate, also called the Pillar Two system. Simultaneously, the European Commission has published a draft directive for implementation of the GLOBE rules at EU-level. The regime relies on implementation of two rules into domestic tax laws and international treaties: an income inclusion rule (IIR) imposing top-up tax on a parent entity in respect of the low-taxed income of a constituent entity; and an undertaxed payment rule denying deductions to the extent that the low-tax income of a constituent entity is not subject to tax under an IIR.
News Source：【Osler 2021/12/23】