By Jefferson VanderWolk Partner, Squire Patton Boggs[1] The GloBE Model Rules were issued in final form in December 2021.  No public consultation was undertaken regarding any draft Model Rules, as there was a need for speed in light of the tight timeline for implementation of Pillar Two’s 15% global minimum tax that had been agreed…

1. The IIR and the top-down approach It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a fundamental overhaul of the international tax system as we know it. As time passes, the international community has time to digest these possible…