OECD Pillar Two — GloBE Rules (Global Minimum Tax) & BEPS
OECD Pillar Two — GloBE Rules (Global Minimum Tax) & BEPS — 50% covered.
4 requirements · 0 enforced · 4 designed · 0 advisory · 0 deferred.
Source: The OECD/G20 Inclusive Framework's Pillar Two introduces the Global Anti-Base Erosion (GloBE) Rules — a 15% global minimum effective tax rate for in-scope multinational groups (consolidated revenue ≥ €750m), implemented via the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR), with a top-up tax computed per jurisdiction and reported in the standardised GloBE Information Return (GIR). KYE Protocol™ governs whether an AI-generated Pillar Two computation (effective-tax-rate, top-up-tax, GIR datapoint) may PROCEED to a consequential action — a filing or a booked liability — under a named preparer's authority with provenance pinned. KYE does not compute the ETR or top-up tax or judge whether the computation is correct. · License: OECD Pillar Two model rules and GIR are published by the OECD; KYE registry cites the rules and the GIR obligation for mapping purposes.
By category
| Category | Reqs | Enforced | Designed | Advisory | Deferred | Coverage |
|---|---|---|---|---|---|---|
| GloBE effective-tax-rate & top-up tax | 2 | 0 | 2 | 0 | 0 | 50% |
| GloBE Information Return (GIR) | 1 | 0 | 1 | 0 | 0 | 50% |
| Scope & charging-rule determination | 1 | 0 | 1 | 0 | 0 | 50% |
Every requirement → the KYE™ artefact that enforces it
| ID | Title | Status | KYE™ enforcement |
|---|---|---|---|
oecd-pillar-two.globe-top-up-tax |
GloBE top-up tax computation due-diligenced before it is filed or booked | designed | rule_packs: kye:rule-pack:tax-governancedictionaries: internalconstitution_refs: constitution/12-PURPOSE-PERMISSION.md |
oecd-pillar-two.effective-tax-rate |
GloBE effective-tax-rate determination provenance-pinned | designed | rule_packs: kye:rule-pack:tax-governancedictionaries: internalconstitution_refs: constitution/13-RESILIENCE-LOOP.md |
oecd-pillar-two.gir-information-return |
GloBE Information Return (GIR) datapoints carry replay-provable data lineage | designed | rule_packs: kye:rule-pack:tax-governancedictionaries: internalconstitution_refs: constitution/13-RESILIENCE-LOOP.md |
oecd-pillar-two.scope-charging-rule |
In-scope determination & charging-rule (IIR/UTPR) selection signed off by a named preparer | designed | rule_packs: kye:rule-pack:tax-governanceconstitution_refs: constitution/36-GOVERNEDUI.md |