Consolidated Commentary to the Global Anti‑Base Erosion Model Rules provides comprehensive guidance on the interpretation and application of the GloBE Rules

On Thursday May 28th, 2026, the report ‘Consolidated Commentary to the Global Anti‑Base Erosion Model Rules (2026)’ of the Inclusive Framework on BEPS was released on the website of the OECD. Addressing the tax challenges arising from the digitalisation of the economy has been a key priority of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS). In October 2021, over 135 jurisdictions joined a ground-breaking plan to ...

Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2025) released

On May 9, 2025 the Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2025) has been released on the website of the OECD. A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the international tax system which is no longer fit for purpose ...