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Antonio Ruiz

Costa Rica
  

OECD and World Bank release GloBE Rules in Spanish

April 08, 2026

EY Law | The Organisation for Economic Co-operation and Development (OECD), in collaboration with the World Bank Group, has released the Spanish version of Global Anti-Base Erosion Model Rules (GloBE rules). This publication provides access in Spanish to Pilar Two of the Two Pillar Approach aimed at addressing the challenges arising from the digital economy.

The GloBE Rules establish a co-ordinated system of taxation designed to ensure that large multinational groups pay a minimum level of tax on the income arising in each jurisdiction where they operate. The rules establish a top-up tax whenever the effective tax rate, which is determined on a jurisdictional basis, falls below the global minimum tax rate agreed (i.e. effective tax rate of 15%).

From a practical standpoint, the Spanish-language version facilitates the comprehension of the content of the rules for Spanish-speaking countries. Consequently, this allows tax authorities that are evaluating the adoption of the rules -or that are in the process of adopting the rules- in their domestic law to do so in a manner that is coherent and aligned with countries that have already adopted the rules.

Currently, these rules have not been adopted in Panama, and few countries in Latin American only partially adopting them. Nevertheless, they will be a useful tool for the authorities’ analysis of its content and potentially for the development of domestic legislation should the country decide to adopt the GloBE rules.

As of today, these rules are in force only in certain countries in Latin America, and even then, they have not adopted all the GloBE rules. Nevertheless, they will be useful for the analysis of their content by tax authorities, who may potentially develop domestic legislation, as well as for multinational companies that could be affected even when a Spanish?speaking jurisdiction has not adopted them.

eylaw.com

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