The OECD public consultation document “global anti-base erosion (globe) proposal: pillar two”: an assessment

This study aims to provide feedback to the OECD on its Public Consultation, launched on 8 November 2019, on the specific matters of the Global Anti-Base Erosion (GloBE) Proposal, also known as Pillar Two of the BEPS 2.0 Project, as included in the Public Consultation Document (The "Public Consultation Document on GloBE"). Some aspects of the latter document have already been the object of a Public Consultation in February 2019. Since the IBFD TFDE has not submitted comments on that specific part of the February Public Consultation, this study also considers issues deriving from that document. Nevertheless, the goal of this study is not to make a comprehensive assessment of GloBE. We will provide that once the initiative reaches its final format. In our view, the consultation is mostly conducted on the basis of the modus operandi of the income inclusion rule. For the purposes of this study, we will use the same baseline. The IBFD TFDE comments, as formulated herein, comprise four sections. Following the overall assessment, each section initially indicates the specific point of the Public Consultation Document on GloBE, then elaborates on the content of the main technical proposal by the IBFD TFDE, and finally includes our contribution to the Public Consultation Document on GloBE. The latter constitutes a subordinate option, which the OECD Secretariat may take into account when evaluating possible amendments to its proposal.