OECDModel Rules on the Pillar Two Global Minimum TaxOn 20 December 2021, the Organisation for Economic Co-operation and Development (OECD) released the Pillar Two Model Rules as part of the two-pillar solution to address the tax challenges arising from the digitalization of the economy. Pillar Two includes two interlocking rules that together comprise the Global Anti-Base Erosion (GloBE) rules: (i) the Income Inclusion Rule; and (ii) the Undertaxed Payment Rule. According to the Model Rules, a Permanent Establishment (PE) is in-scope of the GloBE rules if the head office is part of a Multinational Enterprise (MNE) group subject to the GloBE...