New Administrative Guidance from the OECD/G20 Inclusive Framework on BEPS

This new OECD publication provides new administrative guidance to support the practical application of the GloBE rules.

  • Recapture Rule: guidance on the application of the recapture rule for deferred tax liabilities.
  • Deferred Tax Assets and Liabilities: clarification on determining deferred tax assets and liabilities for GloBE calculation purposes, addressing divergences between GloBE and accounting carrying values.
  • Cross-Border Allocation: guidance on the allocation of current and deferred taxes across borders.
  • Flow-through Entities: allocation of profits and taxes in structures involving Flow-through Entities.
  • Securitisation Vehicles: treatment of securitisation vehicles.

For more details and support, reach out to our team at

Click here to see the publication.

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