On December 20th, 2022, the OECD released a guidance document on Pillar Two Safe Harbours and Penalty Relief, which was approved by the OECD/G20 Inclusive Framework on BEPS on December 15th, 2022. The guidance document is based on stakeholders’ requirements for safe harbours and simplifications to reduce the complexity of performing detailed calculations and meeting burdensome compliance obligations under the OECD Model Rules, particularly with respect to the first years of its implementation. The OECD responded to the call by designing a regulatory framework for a transitional safe harbour rule and a permanent safe harbour rule, as well as proposals for a transitional penalty relief if a multinational group subject to global minimum taxation has taken reasonable measures to ensure the correct application of the corresponding rules. Stefan Bendlinger gives an overview on the guidance and the impact on multinational groups affected by the global minimum tax.
