The OECD confirmed that it intends to provide administrative guidance and multilateral processes, as well as simplification of the rules, stressing that they ‘do not want excessive compliance costs’.

John Peterson, head of the OECD’s aggressive tax planning unit, said: ‘We need more clarity and guidance about the rules. There is a need for consistent interpretation of the model rules by all jurisdictions. We also need guidance on the scope of the transition rules and need to produce a standardised return.

‘In the responses to the consultation on pillar two earlier this year, simplicity was a big emphasis.’

While the complexity of the rules raises issues for multinationals and tax administration bodies, there are also concerns about the timeline for compliance.