OECD

The Organization for Economic Cooperation and Development (OECD) announced that in February 2022 it will put out for public consultation the rules for the implementation in member nations of the 15% global minimum income tax. The tax will apply to multinational enterprises (MNE) with revenues exceeding €750 million, reaching especially those engaged in providing digital services. 

It should be recalled that these rules drawn up by the international organization establish the Global Anti-Base Erosion (GloBE) mechanism. This protocol constitutes a coordinated taxation system so that large groups of multinational companies pay this minimum level of taxation resulting from their operations in each of the jurisdictions involved.

The new rules will help countries to incorporate the new tax mechanism into national legislation. This document provides a coordinated system of interlocking rules that: 

• defines the MNE within the scope of the minimum tax;

• establishes a mechanism for calculating the effective tax rate of an MNE on a jurisdictional basis and for determining the amount of top-up tax payable under the rules; and

• imposes the supplementary tax on a member of the MNE group in accordance with an agreed regulatory order.