全球最低税实施工具包

Global Minimum Tax Implementation Toolkit This work was approved and declassified by theOECDCommittee on Fiscal Affairs on 22April 2026. This document was produced with the financial assistance of the European Union. The views expressed herein can inno way be taken to reflect the official opinion of the European Union. This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty overany territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. Please cite this publication as: OECD (2026),The Global Minimum Tax Implementation Toolkit,OECD Forum on Tax Administration,OECD Publishing,Paris,https://doi.org/10.1787/0ee66d84-en. Attribution4.0 International (CCBY4.0) This work is made available under the Creative Commons Attribution4.0 International licence. By using this work, you accept to be bound by the terms of this licence (https://creativecommons.org/licenses/by/4.0/).Attribution–you must cite the work.Translations–you must cite the original work, identify changes to the original and add the following text:In the event of any discrepancy between the original work and the translation, only the text of originalwork should be considered valid.Adaptations–you must cite the original work and add the following text:This is an adaptation of an original work by the OECD. The opinions expressed and arguments employed in this adaptation should notbe reported as representing the official viewsof the OECD or of its Member countries.Third-party material–the licence does not apply to third-party material in the work. If using such material, you are responsible for obtaining permission from the third party and forany claims of infringement.You must not use the OECD logo, visual identity or cover image without express permission or suggest the OECD endorses your use of the work.Any dispute arising under this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration(PCA) Arbitration Rules2012. The seat of arbitration shall be Paris (France). The numberof arbitrators shall be one. Acknowledgments The project was funded by the European Union via the Technical Support Instrument, andimplementedby the OECD, in co-operation with the European Commission. The work also benefited from financialsupport by other contributors. Table of contents Acknowledgments3 Introduction6 Module 1. Assessing in-scope MNE groups and revenue12 Introduction121.1.Using CbC reports to estimate the population of in-scope MNE Groups in ajurisdiction131.2.Commercial datasets201.3.Other sources of data to estimate in-scope population241.4.Estimating top-up tax revenue28 Module 2. Legal Implementation 34 Introduction342.1.Legislative techniques362.2Legislative techniques for updating domestic law422.3.Interpretation mechanisms46 Module 3. Organising and Planning for the Implementation of the GMT 49 Introduction493.1.Implementation plan493.2.Assessing key tax administration functions and need for changes51 Module 4. Framework on Compliance Procedures68Introduction684.1GMT Compliance procedures and best practices69 Module 5. Exchange of Information Introduction855.1.Legal implementation of the exchange of information under the GloBE Rules865.2.Operational implementation of exchange of information of the GIR91 FIGURES Figure1. The GMT implementation roadmap11Figure2. Applying filters to aggregated CbC reporting data in the OECD Data Explorer25Figure3. Estimating the number of in-scope MNE groups by UPE jurisdiction using aggregated CbC reportingdata26 Figure4. Calculation of top-up taxes under GloBE28Figure5. External communication objectives and channels60Figure6. IT Functionalities for GMT Compliance61Figure7. Key Steps of the GMT Compliance Procedures69 TABLES Table1. Ownership data from Orbis is relatively complete21Table2. Key data scenarios and recommended data sources29Table3. Comparison of ambulatory and static approach of cross-reference39Table4. Overview of the key tax administration functions52Table5. Dissemination approach for the General Section94Table6. Dissemination approach for the Jurisdictional Section(s)95 Introduction 1.TheGlobal Minimum Tax (GMT)agreed in 2021 by the Inclusive Framework on BEPS (IF) consistsof a coordinated set of rules-the Global Anti-Base Erosion (GloBE) Rules1, as complemented by aCommentary and Administrative Guidance2-designed to ensure that large multinational enterprises(MNE) are subject to a minimum level of tax in each jurisdiction where they operate.Where the level of taxis below the agreed minimum,thetop-up tax is either collected by the low-tax jurisdiction itself, under a socalled Qualified Domestic Minimum Top-up Tax (QDMTT), or, where no QDMTT applies, by anotherimplementing jurisdiction through the imposition of either: a.an Income Inclusion Rule (IIR) which imposes top-up tax on a parent entity in respect of the lowtaxed incom