GloBE (Global Anti-Base Erosion rules)
GloBE stands for Global Anti-Base Erosion. It is the set of model rules, agreed at the OECD/G20 Inclusive Framework, that delivers the Pillar Two global minimum tax in practice. It has two main mechanisms. The Income Inclusion Rule (IIR) lets the country of a parent company charge a top-up tax when one of its subsidiaries is taxed below the 15% minimum. The Undertaxed Profits Rule (UTPR) is the backstop: where no IIR has applied, it lets other countries in the group deny deductions or make an equivalent adjustment to collect the shortfall. Together they make 15% hard to undercut, because if one country does not collect the top-up, another can. The rules apply to groups with revenue of €750m or more.
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Example: a low-taxed subsidiary escapes a top-up in its own country, so under the IIR the parent's country charges the difference up to 15%; if that fails too, the UTPR lets other group countries collect it.
Why it matters to a small business: GloBE is the machinery behind the minimum tax on large groups. It does not touch small firms (the €750m threshold sees to that), but it is the closest the system has come to a floor under the rate that giants pay.