The OECD Inclusive Framework continues to provide further guidance on the interpretation and application of the Pillar II rules in order to enable their consistent application and to provide simplifications where possible. The fourth set of the Agreed Administrative Guidance covers a range of areas such as the practical application of the DTL recapture rule, how to deal with divergences between Pillar II and accounting carrying values, the allocation of cross-border current and deferred taxes, the allocation of profits and taxes in groups including flow-through entities, as well as the treatment of securitization vehicles.
