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Article 8.3.1 contemplates that further guidance on the interpretation or application of the GloBE Rules may be agreed and published by the Inclusive Framework. This Article ensures that when such guidance is issued, it is applied in a co-ordinated way.

There are a number of places in the GloBE Rules where determinations by one tax administration are likely to have corresponding consequences for the application of the GloBE Rules in other jurisdictions. In these cases, tax administrations can collaborate with each other through the Inclusive Framework to determine whether a co-ordinated solution to these questions can be agreed. If the discussions at the level of the Inclusive Framework result in the development of Agreed Administrative Guidance, then Article 8.3.1 provides that a tax administration should interpret and apply the GloBE Rules in accordance with that Agreed Administrative Guidance, subject to any other requirements under domestic law. For example, the domestic law of some Inclusive Framework members would not permit them to simply refer to that Agreed Administrative Guidance to interpret and apply the GloBE Rules. Their domestic law may instead permit the tax administration to adopt that Agreed Administrative Guidance by incorporating it verbatim or in substance into its own administrative guidance. Some Inclusive Framework members may need parliamentary acceptance of the Agreed Administrative Guidance before it could be used to interpret or apply the GloBE Rules.