On 22 December 2021, the European Commission proposed a Directive on the introduction of a minimum effective corporate tax rate of 15% on large multinational enterprise (MNE) groups operating in the European Union (EU).  The draft Directive follows the publication by the Organization for Economic Cooperation and Development (OECD) of the Pillar II Model Rules (also referred to as the Global Anti-Base Erosion (GloBE) rules) designed to ensure that large MNEs pay a minimum level of tax on the income arising in each jurisdiction where they operate.