New OECD Guidelines for Tax Base Erosion

June 24, 2024

Implementation of Pillar Two Rules  

In June 2024, the OECD published new administrative guidelines for global anti-tax base erosion rules, known as Pillar Two. These guidelines seek to standardize the implementation of the rules to ensure that multinationals pay a minimum amount of tax in all countries where they operate, combating tax evasion and promoting fairness.  

 Objectives and Scope of the Guidelines  

 The main objective of these guidelines is to establish a consistent and transparent framework for the imposition of a global minimum tax. This minimum tax ensures that multinationals cannot evade their tax liabilities by shifting their profits to low or no tax jurisdictions.  

 Requirements for Multinational Enterprises  

 Multinational companies are required to adjust their tax and accounting policies to comply with the new standards. The guidelines detail the procedures for reporting and calculating the global minimum tax, which will apply to income generated in all jurisdictions where these companies operate.  

 Impact on the Global Economy  

The OECD guidelines are expected to have a significant impact on the global economy. They will reduce tax avoidance practices, increase transparency and encourage fairer competition between companies. OECD member countries will need to adapt their national legislation to align their tax systems with these new standards.  

 Challenges and Opportunities  

 While the implementation of these guidelines presents challenges, it also offers opportunities to strengthen national tax systems and promote global tax fairness. Companies will need to invest in resources to adapt to these changes, but in the long run, this could result in a more stable and predictable tax environment.  


The new OECD guidelines represent significant progress towards global tax fairness, promoting fair competition and combating tax base erosion. This internationally coordinated effort will help ensure that companies contribute fairly to the economies in which they operate, benefiting all countries involved.