GloBE Rules Made Easy

By: Kuldeep Sharma

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eText | 9 December 2022

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Worldwide implementation of the OECD's Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules.

The book includes such features as the following:

text of each of the Rules' ten chapters (including all forty-nine articles) along with both summary and detailed description;
explanations of the Commentary and Illustrative Examples released by the OECD in March 2022;
numerous flowcharts, tables, boxes, illustrations, and figures;
elaborate technical discussions amidst specific policy considerations;
analysis of IF Member jurisdictions regarding key parameters with suitable recommendations;
'GloBE Rules at a Glance' checklist encapsulating the features and application of the Rules in the form of FAQs; and
implementation processes under way in ten representative jurisdictions.

The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained.

In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.