Overview
- The OECD/G20 Inclusive Framework said 147 jurisdictions agreed on a coordinated package to implement a 15% effective minimum corporate tax.
- The package creates a qualified parallel regime, with the U.S. Treasury stating that U.S.-headquartered groups would follow U.S. global minimum rules and be exempt from Pillar Two where the regime applies.
- The agreement features five elements: simplification measures, a new specific fiscal safeguard, safeguards for groups based in eligible jurisdictions, an evidence-based evaluation process, and reinforcement of qualified domestic minimum top-up taxes.
- The new safeguard will be available to multinational groups from early 2027, or from early 2026 in certain circumstances, according to the OECD text.
- Participants committed to review the parallel system in 2029 to address potential risks and competitiveness issues, with Ireland backing the approach as consistent with G7 and G20 requests.