With the Organisation for Economic Co-operation and Development's (OECD) Pillar 2 Global anti-Base Erosion (GloBE) Rules now in play, understanding who, what, and how the regime will impact multinational enterprises (MNEs) is vital. With new OECD guidance being steadily released,...

The OECD two-pillar approach In October 2021, the OECD’s 137 Inclusive Framework members agreed to adopt a two-pillar approach to address the tax challenges of the digital economy. Pillar I provides for new profit allocation and nexus rules for MNEs...