International tax reform: OECD/G20 Inclusive Framework releases new information on key aspects of the Two-Pillar Solution


18/12/2023 – Today, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) released further technical guidance to assist governments with implementation of the global minimum tax under Pillar Two and a statement on the timeline of the Multilateral Convention (MLC) under Pillar One.


The Agreed Administrative Guidance for the Pillar Two GloBE Rules (December 2023) released today supplements the Commentary to the Global Anti-Base Erosion Model Rules in order to clarify their application, including guidance on the application of the Transitional Country-by-Country Reporting Safe Harbour and a mechanism for allocating taxes arising in a Blended Controlled Foreign Corporation (CFC) Tax Regime when some of the jurisdictions the MNE operates in are eligible for the safe harbour.


The Inclusive Framework will continue to release further Agreed Administrative Guidance on an ongoing basis in response to stakeholder requests for clarification of various aspects of the GloBE Rules and, where necessary, to address aggressive tax planning that may undermine the integrity of the rules or their application to certain MNE Groups. The Inclusive Framework will also continue to develop simplifications on key compliance items on a timely basis, which includes guidance expected in the first half of 2024 on the application of deferred tax liability recapture rules and the allocation of deferred taxes relating to cross-border taxes such as CFC Tax Regimes. The Inclusive Framework will also implement a robust and transparent peer review process and continue the ongoing work on the administrative framework and dispute resolution mechanisms with a view to providing a high level of tax certainty to stakeholders in applying the rules.


The Inclusive Framework also released today a statement updating the timeline to finalise the text of the MLC to implement the coordinated reallocation of taxing rights over the profits of the world’s largest and most profitable companies (Amount A of Pillar One). The statement expresses the continued and strong commitment of Inclusive Framework delegates to resolve the outstanding issues, achieve a consensus-based solution and finalise the text of the MLC as swiftly as possible.


For further information, journalists are invited to contact Manal Corwin (+33 1 45 24 18 80), Director of the OECD Centre for Tax Policy and Administration, or


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