On December 20th, 2021, the OECD Inclusive Framework finally published the long-awaited OECD Model Rules for the implementation of a global minimum taxation regime (Pillar II or GloBE). The template for national legislators, originally announced as early as November 30th, 2021, contains a 45-page extremely complex and comprehensive set of rules with an additional 15 pages of necessary legal definitions. If the OECD has its way, national legislators should transpose the rules into domestic laws as early as 2022 and they should already become effective in 2023. Only two days after the release of the OECD Model Rules, the European Commission showed a strong commitment and also published a proposal for a directive which is strongly based on the OECD proposed draft legislation. In this article, Valentin Bendlinger provides a first commentary on the comprehensive set of rules for a future system of global minimum taxation and its planned implementation within the EU.
