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May 15, 2026

CHAPTER 18 - FINAL PROVISIONS

Article 116 - Application of GloBE Rules

The provisions of these ERs shall be interpreted and applied in accordance with international documents, including any amendments, as detailed:

  1. The OECD Global Anti-Base Erosion Model Rules (GloBE), under the Inclusive Framework on BEPS – Addressing the Tax Challenges Arising from the Digitalization of the Economy – OECD (2021).

  2. The Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2025), Tax Challenges Arising from the Digitalization of the Economy (2024).

  3. Any subsequent amendments or additions to the international documents referred to in clause (1) and (2).