OECDOECD releases administrative guidance for Pillar TwoOn 2 February 2023, the Organisation for Economic Co-operation and Development released Administrative Guidance (the guidance) for the implementation of the global minimum tax. Among other items, the guidance addresses questions related to Permanent Establishments (PEs). For example, it clarifies that if the Main Entity is considered an Excluded Entity, then all its activities, including those performed by its PEs, are excluded from the Global Anti-Base Erosion (GloBE) Rules.Another topic addressed is the calculation of the Qualified Domestic Minimum Top-up Tax (QDMTT). Accordingly, a jurisdiction with a taxable branch regime must exclude the income...