The OECD has published an updated Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2025). The Consolidated Commentary incorporates administrative guidance that has been released by the Inclusive Framework from March 2022 to March 2025.
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Abstract
A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the i…