This process also involves collecting input from the various stakeholders as part of a public consultation process. The IF will further develop an Implementation Framework to support local tax authorities in the implementation and administration of the GloBE Rules. With the publication of the Commentary and the examples, the next important phase of this OECD Pillar Two project is being approached. This would be done as part of the Implementation Framework through specific Administrative Guidance. It is likely that additional examples might be developed and published in the future to illustrate how some of the GloBE Model Rules shall work. The document has an illustrative purpose only and the examples do not form part of the Commentary as such. The document with the examples illustrates the application of some of the GloBE Rules.
As such, it explains the intended outcomes under the GloBE Model Rules and clarifies the meaning of certain provisions. The Commentary shall ensure a consistent and common interpretation of the previously published GloBE Model Rules with the aim of facilitating coordinated outcomes for both the tax authorities as well as MNE groups.
