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OECD: 147 Countries & Jurisdictions Agree to Key 5 Components of Corporate Tax Arrangements & Minimum 15% Corporate Tax Rate for Multi-National Enterprises

6th January | Hong Kong 

OECD has announced 147 countries & jurisdictions have agreed to key 5 components of corporate tax arrangements & minimum 15% corporate tax rate for multi-national enterprises.  In 2021 October, OECD announced 136 countries and jurisdictions representing 90% of global GDP agreed to both 15% minimum corporate tax rate and large multi-national enterprises (MNEs) to pay tax where they operate and earn profits.  The new 2-pillar plan will reform international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate, has been finalised on the 8th of October 2021 and will be implemented in 2023.  The landmark deal will also reallocate more than $125 billion of profits from around 100 of the world’s largest and most profitable MNEs to countries worldwide.  In 2021 June, the G7 Nations United States, Japan, Germany, Britain, France, Italy and Canada agreed to a new minimum global corporate tax rate of at least 15% on overseas earnings. (OECD ~ Organisation for EconomicCo-operation and Development).  Announcement (5/1/26): “The 147 countries and jurisdictions working together within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) have agreed on key elements of a package that charts a course forward for the co-ordinated operation of global minimum tax arrangements in the context of a digitalised and globalised economy.  Following months of intense negotiations, the comprehensive package for a side by side” arrangement announced today represents a significant political and technical agreement which will set the foundation for stability and certainty in the international tax system. It will preserve the gains achieved so far in the global minimum tax framework and protect the ability for all jurisdictions, particularly developing countries, to have first taxing rights over income generated in their jurisdictions.  The package includes five key components: 1) First, a series of simplification measures will reduce compliance burdens for multinational enterprises (MNEs) and tax authorities in calculating and reporting under the global minimum tax rules. 2) Second, the package further aligns the treatment of tax incentives globally through the introduction of a new targeted substance-based tax incentive safe harbour. 3) Third, new safe harbours are available to MNE Groups having an ultimate parent entity located in an eligible jurisdiction which meets minimum taxation requirements. 4) Fourth, the package includes an evidence-based stocktake process to ensure a level playing field is maintained for all Inclusive Framework Members. 5) Fifth, the package reinforces the objective that qualified domestic minimum top-up tax regimes remain a primary mechanism in the global minimum tax framework for ensuring the protection of local tax bases, particularly in developing countries … …  Additional tools and fact sheets to support implementation of the package will be made available in the coming weeks, alongside a dedicated webinar hosted by the OECD on 13 January 2026. The OECD will also continue to ensure that the rules can be implemented effectively and efficiently by all countries and jurisdictions, offering comprehensive capacity-building assistance where needed.”

“ OECD: 147 Countries & Jurisdictions Agree to Key 5 Components of Corporate Tax Arrangements & Minimum 15% Corporate Tax Rate for Multi-National Enterprises “

 



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OECD: 147 Countries & Jurisdictions Agree to Key 5 Components of Corporate Tax Arrangements & Minimum 15% Corporate Tax Rate for Multi-National Enterprises

European Countries



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