Global Anti-Base Erosion Model Rules

‘‘Global Anti-Base Erosion Model Rules’’ or ‘‘GloBE Model Rules’’

means the set of rules as developed by the Inclusive Framework, applied in accordance with Part II of this Act, and—

(a)	set out in the document titled Tax Challenges Arising from the Digitalisation of the Economy Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS, which is a document—

(i)	approved by the Inclusive Framework on 14 December 2021; and

(ii)	published by the OECD; and

(b)	as amended and released from time to time, except any amendments to the definition of minimum rate in Article 10.1.1 of the GloBE Model Rules referred to in paragraph (a), as specified under section 23;

[Paragraph (b) substituted by section 63(1)(b) of the Taxation Laws Amendment Act, 2026, Notice No. 7344, GG54448, dated 1 April 2026 - deemed to have come into operation on 1 January 2024 (section 63(2))]