F.1 Introduction

In October 2021, more than 135 countries and jurisdictions agreed to participate in a “two-pillar” international tax approach developed by the OECD, which includes establishing a global minimum corporate tax rate of 15 percent. The OECD published Tax Challenges Arising From the Digitalisation of the Economy — Global Anti-Base Erosion Model Rules (Pillar Two)1 in December 2021 and subsequently issued additional commentary and administrative guidance2 clarifying several aspects of the GloBE rules.

Since that time, certain countries have enacted Pillar Two–related laws, some of which became effective January 1, 2024, and we anticipate that many more will follow suit. Accordingly, this appendix provides responses to some frequently asked questions (FAQs) about how an entity should account for the tax effects of the GloBE rules in accordance with ASC 740 in interim and annual periods. It also incorporates guidance from certain previously issued Deloitte publications. While the answers to the FAQs reflect our current positions, these views are subject to change (e.g., on the basis of additional guidance, new information, or changes in practice). Consultation with an entity’s accounting advisers is encouraged.

We plan to continue to update this appendix as developments occur or additional questions arise.