OECD releases Pillar Two implementation package

January 23, 20230

During December 2022, the OECD/G20 Inclusive Framework on BEPS released an implementation package regarding the Pillar Two Global Anti-Base Erosion (GloBE) Rules, which ensure that multinational enterprises with a consolidated annual revenue exceeding EUR 750 million pay a minimum tax rate of 15% on a jurisdictional level.


The implementation package contains three documents:

  1. Guidance on Safe Harbours and Penalty Relief which relieves MNEs from performing full GloBE calculations for low-risk jurisdictions during an initial period, as they deal with the complexity of the requirements and build the necessary systems for collecting accurate data. The document also outlines a regulatory framework for the development of a potential permanent safe harbor, as well as a common understanding for a transitional penalty relief regime.
  2. A public consultation document on GloBE Information Return that seeks input on the amount and type of information that MNEs collect, store and/or report for applying the GloBE Rules, possible simplifications for the GloBE Information Return, as well as the possibility for MNEs to provide alternative data points.
  3. A public consultation document on Tax Certainty for the GloBE Rules that lists various mechanisms, covering both dispute prevention and dispute resolution, for achieving tax certainty under the GloBE Rules. It outlines the expected next steps for the development of the mechanisms and identifies a number of areas where input would be valuable.


The Inclusive Framework expects to release administrative guidance on the interpretation or application of the global minimum tax rate on an ongoing basis, with the first package expected in early 2023.


For further consultation on the applicability and implementation of the Pillar Two GloBE rules for your organization, please contact:

Jasper Verkamman, Associate

Raymund Gerardu, Managing Partner


Read more about Pillar Two here.

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