In January 2025, the OECD provided some much-needed guidance on the operation of the Pillar 2 GloBE rules, which can be summarized as follows:

• Each jurisdiction that has enacted Pillar 2 must calculate an MNE’s Pillar 2 tax liability using the locally enacted Pillar 2 legislation;
• These calculations could be different from a similar calculation completed using OECD model rules for several rea…