The document then emphasises the importance of coordination, for example also when it comes to determining the scope of the measures. Consistency in the implementation and administration of the GloBE Rules is intended to result in a transparent and comprehensive system of taxation that provides predictable outcomes for MNEs and avoids the risk of double or over-taxation.”Ĭonsistency, that sounds good, although it is still a question of how we are going to guarantee that (legally) but that aside. A jurisdiction that joins the common approach is not required to adopt the GloBE Rules but, if it chooses to do so, it agrees to implement and administer them in a way that is consistent with the outcomes provided under the GloBE Rules and this Commentary. The GloBE Rules are intended to be implemented as part of a common approach. On page 11 of the Commentary there are some passages about the importance of a coordinated and consistent approach, under the heading ‘Co-ordination and consistency requirements under common approach’. This, in addition to some thoughts that came to mind about the ever-changing nature of the measures and which I would like to save for another time. The sentence is a comment on the hypocrisy of governments that proclaim the absolute equality of their citizens but give power and privileges to a small elite.” I was suddenly reminded of this when I put together some of the passages in the commentary from the Introduction and Chapter 1, including the commentary on Article 1.1 on the scope of the measures. On I read that this is about: “A proclamation by the pigs who control the government in the novel Animal Farm, by George Orwell. You are undoubtedly familiar with George Orwell’s novel Animal Farm, and otherwise the famous proclamation from the book: ‘All animals are equal, but some animals are more equal than others’. Already after reading the first pages, I was overwhelmed by the urge to write this opinion piece. Yesterday, on 14 March 2022, the OECD published the Commentary on the Pillar 2 Model Rules, the global minimum rate for large multinationals and the additional levy up to that minimum rate where countries do not comply with the minimum. When reading the first pages, the author was overwhelmed by the urge to write this opinion and, ‘equally, however’, to make a connection with an animal farm.
Yesterday, on 14 March 2022, the OECD published the Commentary on the Pillar 2 Model Rules, the global minimum rate for large multinationals.
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