Executive summaryOn 22 December 2021, the European Commission (the Commission) published a legislative proposal for a Directive setting forth rules to ensure a global minimum level of taxation for multinational groups (the draft Directive). The proposed rules are generally consistent with the agreement reached by the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) on 8 October 2021 (the October Statement),1 and closely follow the Model Rules published on 20 December 2021.2In its October Statement, the Inclusive Framework announced the global minimum tax rules as a common approach. This means that jurisdictions are not obliged to introduce a minimum tax approach, but...