Consistency versus “Gold Plating”: The EU Approach to Implementing the OECD Pillar Two
Journal
European Union; International; OECD
Bulletin for International Taxation 2022 (Volume 76), No. 4
This article considers the proposed EU Directive to transpose the OECD Global Anti-Base Erosion (GloBE) Model Rules into EU secondary law. It describes the key aspects of the rules, notes the differences between the EU proposal and the OECD Model Rules, and demonstrates how the new charging provisions will operate.