On 20 December 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting, involving 137 countries, released Model Global Anti-Base Erosion (GloBE) Rules under Pillar 2. The Commentary to these rules has not been released at this time however and this is now likely to be released after the OECD return from their holiday break in January 2022. The Subject to Tax Rule has also not ...