Pillar Two of the Inclusive Framework on BEPS

Adopting a practical problem-solving approach, this book critically analyses the recent OECD Global Anti-Base Erosion Model Rules that have been adopted to address the tax challenges arising from the digitalisation of the economy. It provides a clear and systematic explanation of Pillar Two and the OECD policies, which are now being implemented in a variety of national tax systems.

Key Features:







Exploration of the scope of the GloBE Rules


Accessible explanations of technical jargon accompanied by examples


Focus on key concepts of GloBE Income or Loss and Adjusted Covered Taxes


Concise descriptions of each area of OECD policies on the global minimum tax


Investigation into the mechanism currently being used to apply the global minimum tax


Examination of domestic qualified minimum taxes that align with OECD standards


Analysis of tax neutrality and distribution regimes



This thorough and authoritative guide is an indispensable resource for tax lawyers, tax managers of multinational firms, tax professionals, and tax administrations and international organisations. The book’s expert analysis of complex tax reporting procedures for multinational companies is also beneficial to academics and researchers of corporate tax and international taxation.