The Global Minimum Tax

Abstract

In October 2021, a historic two-pillar international agreement was reached among 137 countries of the OECD/G20 Inclusive Framework on BEPS to address the twin challenges of globalization and digitalization. Pillar One will reallocate tax revenues to the country of the consumer. Pillar Two introduces a global minimum effective tax for MNEs (GMT). This paper focuses on implementation of the GMT. It provides an overview of the core GMT rules, examines implementation by countries thus far, evaluates the key policy considerations (including the impact on tax incentives), and provides a framework for evaluation of the implementation options. The paper also makes recommendations on practical steps in the implementation process, including administrative issues and consultation with key stakeholders. These discussions are expected to be particularly relevant for developing countries.