New OECD Transfer Pricing Guidelines and Their Impact

May 2, 2024

Introduction to the GloBE Rules

The Global Base Erosion and Profit Shifting (GloBE) rules formulated by the OECD in 2024, also known as the Second Pillar of the Global Minimum Tax, aim to minimize taxable base erosion and profit shifting. This approach significantly affects multinational groups regarding the management of their international tax obligations and income reporting.  

International Activity Assessment

A multinational group must first determine whether it operates internationally to be subject to the GloBE rules. It is established if two or more entities  a Ultimate Parent Entity (UPE) are, or would be, included in the consolidated financial statements thereof. This initial step is essential to establish the responsibility under these new regulations.  

Determining the Earnings Threshold

Additionally, the group must be verified whether it exceeds the €750 million revenue threshold in two of the last four tax years. This quantitative criterion allows for identifying which conglomerates need to adhere to these regulations rigorously to avoid penalties.  

Exclusions and Special Considerations

Not all entities of a multinational group are subject to these rules. Identifying the excluded ones is essential, especially because their revenues are still considered in determining whether the necessary threshold is met. This distinction assists companies in better planning their tax compliance strategies.  


Properly implementing the GloBE rules requires a clear understanding of corporate structure, general revenues, and international transactions. Companies should strive to keep thorough records and comply with declarations to avoid penalties under these OECD rules.