GloBE Administrative Guidance – The QDMTT and GILTI Allocation

On 2 February 2023, the OECD/G20 Inclusive Framework released a package of Administrative Guidance for the Pillar Two GloBE Rules. The package addressed a variety of key outstanding issues which had been subject to ongoing negotiations by the Inclusive Framework’s Working Party 11. This Policy Brief addresses the following three developments/clarifications:

1) the GILTI regime is a CFC Tax Regime;
2) the QDMTT applies before CFC Taxes; and
3) there is a new allocation mechanism of GILTI as a Blended CFC Tax.


Heydon Wardell-Burrus