The OECD has published model rules to give effect to its Global Anti-Base Erosion (GLoBE) regime requiring large multinational enterprises to pay a 15 per cent minimum tax rate on income arising in each of the jurisdictions where they operate, also called the Pillar Two system. Simultaneously, the European Commission has published a draft directive for implementation of the GLOBE rules at EU-level. The regime relies on implementation of two rules into domestic tax laws and international treaties: ...