OECD PE developmentsOECD releases additional Administrative Guidance on Pillar TwoOn 18 December 2023, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released additional Administrative Guidance on the Global Anti-Base Erosion (GloBE) Model Rules, which provide information on a series of technical issues under the GloBE Rules, including issues related to Permanent Establishments (PEs).The December Guidance addresses some areas related to the Transitional Country-by-Country Reporting (CbCR) Safe Harbour that tax administrations and Multinational Entity (MNE) Groups identified as requiring further clarification. One of these areas involves the Qualified Financial Statements (QFSs) for PEs. In cases where a QFS...