Global minimum tax / Advanced
GloBE Model Rules — Pillar Two
The operative model framework for the global minimum tax, including scope, computations and key definitions.
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The T&M reading note
Why it deserves your time
Provides the base text behind the expanding commentary and administrative guidance.
A suggested 15-minute first pass
Where to begin
- Identify the scope provisions.
- Follow the income, covered-tax and top-up-tax structure.
- Read with the commentary and later guidance.
Read this edition in context
Foundational 2021 model text. Implementation depends on domestic legislation; later guidance remains important.
These notes describe the publication; they do not determine the treatment of a particular taxpayer or transaction.
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Official sourcewww.oecd.org Catalogue review: 2026-10-13