Die OECD Model Rules für ein globales Mindestbesteuerungsregime

On December 20th, 2021, the OECD Inclusive Framework finally published the long-awaited OECD Model Rules for the implementation of a global mi nimum 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 se t 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 sh ould already become effective in 2023. Only two days after the release of the OECD Model Ru les, the European Commission showed a strong commitment and also published a proposal for a directive which is strongly based on the OECD proposed draft legislatio n. 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.