OECD developmentsOECD releases fourth batch of Administrative Guidance, including new rules for allocating taxes to foreign PEsOn 17 June 2024, the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework released a fourth tranche of Administrative Guidance on the Pillar Two Global Anti-Base Erosion (GloBE) Rules. Among other items, the June 2024 Administrative Guidance provides new rules on how to allocate current and deferred taxes, including taxes that may be pushed down to a foreign Permanent Establishment (PE).Regarding current taxes, the June 2024 Administrative Guidance provides a common mechanism to push down an amount of the taxpayer's current taxes to...