On March 14, the Organization for Economic Cooperation and Development (OECD) published the Commentary on the Global Base Erosion Rules (GloBE) where it presents specific details on the operation of the new global minimum tax that will apply to all multinational companies earning at least 750 million euros per year. The entity also opened a public consultation for private parties to answer a series of questions on the implementation of these rules. Interested parties may send their opinions until April 11 via email to [email protected]
The document presented is not directly related to the new public consultation. In that sense, the comments seek to clarify the technical and specific details that should guide governments that have signed the global tax agreement in applying the 15% minimum rate.
The new public consultation, according to the OECD, is part of the next step in the development of the GloBE Rules. In this sense, work will now begin to develop the implementation mechanism of the agreement. Thus, the entity is requesting all interested private parties to send their opinions, answering the following questions:
- Do you see a need for further administrative guidance as part of the Implementation Framework? If so, please specify the issues that require attention and include any suggestions for the type of administrative guidance needed.
- Do you have any comments relating to filing, information collection including reporting systems and record keeping? In particular, do you have any views on how the design of the information collection, filing obligations and record keeping requirements under GloBE could be designed to maximize efficiency, accuracy and verifiability of information reporting while taking into account compliance costs?
- Do you have any suggestions on measures to reduce compliance costs for Multinational Enterprises (MNEs) including through simplifications and the use of safe-harbors?
- Do you have views on mechanisms to maximize rule coordination, increase tax certainty and avoid the risk of double taxation?
The international organization explains that this feedback will seek to improve the proposal in order to implement and apply the GloBE Rules in a consistent and coordinated manner, while minimizing compliance costs. The contributions must be sent in Word format and will be addressed to the OECD’s International Tax and Cooperation Division. The entity also informed that in April 2022 it will carry out a virtual public consultation where all interested parties will be able to participate and provide their contributions. The date for this event has not yet been confirmed.