Pillar Two model rules for domestic implementation of a global minimum tax

The rules and guidance published by the OECD define the scope and set out the mechanism for the so-called Global Anti-Base Erosion (GloBE) rules under Pillar Two, which will introduce a global minimum corporate tax rate set at 15%. The GloBE rules provide for a co-ordinated system of taxation intended to ensure large MNE groups pay this minimum level of tax on income arising in each of the jurisdictions in which they operate.


  • The EBC recommends that the introduction of Pillar Two rules in Japan should be minimise administrative burdens and be sensitive to the impact on and overlap with Japanese Controlled Foreign Corporation rules.