OECD Pillar Two: Administrative guidance published

On 2 February 2023, the OECD announced the release of the long-awaited “administrative guidance” on Pillar Two (the OECD's global minimum tax). This updates the commentary released in March 2022 and addresses a number of the open technical uncertainties in the Pillar Two rules.

The new guidance is 111 pages long and covers questions of scope, income and taxes, insurance-specific points, transition, and qualified domestic minimum top-up taxes (QDMTTs).

The guidance will be incorporated into the Pillar Two commentary (and a revised synthesized version of the commentary is expected to be released later in 2023). As previously announced, the OECD will continue to update the administrative guidance/commentary on an ongoing basis to ensure consistency in the application of the Pillar Two rules.