Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union was published in the Official Journal of the European Union on 22 December 2022. The Directive provides for the implementation of the OECD's Pillar 2 global minimum tax (GloBE) rules in the EU, including the income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR). The GloBE rules essentially provide for the collection of an additional amount of tax (a top-up tax) when the effective tax rate of an MNE in a given...