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OECD: Inclusive Framework on BEPS releases updates to global minimum tax administration

Additional administrative guidance under the Pillar Two rules

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January 15, 2025

The Organisation for Economic Cooperation and Development (OECD) today announced additional administrative guidance under the Pillar Two rules, including several developments aimed at streamlining the administration of the global minimum tax.

According to today鈥檚 , key releases include:

  • : This document lists jurisdictions whose minimum tax legislation has completed the fast-track process and secured transitional qualified status. It will be updated regularly to include additional jurisdictions.
  • : This guidance excludes certain deferred tax assets from the computation of an MNE group鈥檚 effective tax rate when they arose before the global minimum tax application due to specific governmental arrangements or the introduction of a new corporate income tax. Jurisdictions may need to amend domestic legislation to apply aspects of this guidance.
  • : The updated GIR, initially released in July 2023, includes simplifications and clarifications based on stakeholder feedback. It also features a new annex with an optional notification template for jurisdictions requiring notification from MNE groups about receiving the GIR through information exchange.
  • and related tools: The GIR MCAA outlines conditions for the automatic exchange of GIR information under the . The provide a common electronic format for the GIR, with further work planned on validation rules to ensure data consistency and quality before filing and exchange.

The OECD today also released on the qualified status under the global minimum tax in 鈥渜uestion and answer鈥� (Q&A) format.

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