The OECD has released the Pillar Two Model Rules (explained also in a nutshell by the OECD), which provide a template for jurisdictions to translate the Pillar Two rules into domestic law in a coordinated and timely way.   

The OECD's Two-Pillar Solution, agreed to in July 2021 by over 131 countries, addresses the global taxation issues arising from the digitalisation of the economy. The finalised framework, including details on how to implement the rules, was agreed to in October 2021.

Pillar Two consists of two rules intended for introduction in national domestic tax laws -together known as the Global anti-Base Erosion (GloBE) rules -as well as a treaty-based rule. The OECD Model Rules contain provisions in respect of the GloBE Model Rules only.

Countries agree on finalised framework for OECD global tax reform