In December 2022, the OECD Inclusive Framework on BEPS published a set of Global Anti-Base Erosion Model Rules for the implementation of a global minimum tax (Pillar II) followed by the EU Commission’s proposal for a corresponding Council Directive, which was agreed upon by the EU member states on December 15^th/16^th, 2022, which shall become effective for fiscal years starting on January 1^st, 2024. Moreover, non-EU member states have already announced that they will implement the global minimum tax on domestic basis to become effective in 2024 as well. Some states have started a public consultation process, and some have already published draft legislation. The general approach of the OECD and EU Model Rules is to identify low-taxed jurisdictions in which the operations of a multinational group are taxed at an effective tax rate that is below the agreed minimum tax of 15 percent. As a principle, an income inclusion rule requires that the top-up tax in general be collected at the level of the ultimate parent entity. Income and taxes to be allocated to a group’s constituent entities have to be calculated based on the financial accounting net income or loss rather than on a tax basis....