In January 2025, the OECD provided some much-needed guidance on the operation of the Pillar 2 GloBE rules, which can be summarized as follows: Each jurisdiction that has enacted Pillar 2 must calculate an MNE’s Pillar 2 tax liability using the locally enacted Pillar 2 legislation; These calculations could be different from a similar calculation completed using OECD model rules for several reasons; Because of the common approach agreed to by all jurisdictions that have agreed to enact Pillar 2, there is a rule order which means jurisdictions that have enacted a lower priority rule order (e.g., IIR or UTPR)...