138 Countries and Jurisdictions Reach Historic Landmark Agreement on International Tax Reform

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On 11 July 2023, 138 members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), representing over 90% of global GDP, agreed upon an Outcome Statement.


The reforms, known as the Two-Pillar Solution, aim to achieve a fairer distribution of profits and taxing rights among countries and jurisdictions, with a specific focus on the world's largest Multinational Enterprises (MNEs). The Outcome Statement reflects the collaborative efforts and compromises made by jurisdictions of all sizes, including both developing and developed nations, during 20 months of intense technical negotiations.

The Outcome Statement, which emerged from the 15th Meeting of the Inclusive Framework (IF), is the culmination of 20 months of intense technical negotiations by delegates. It reflects a spirit of collaboration and compromise among jurisdictions of all sizes, encompassing both developing and developed nations. These negotiations have been ongoing since October 2021 and have laid the groundwork for substantial reforms in the international tax landscape.

The Outcome Statement highlights the deliverables developed by the IF to address the remaining elements of the Two-Pillar Solution, including a Multilateral Convention (MLC), a simplified framework for the arm's length principle, the Subject-to-Tax Rule (STTR), and a comprehensive action plan for coordinated implementation.

Read the full OECD release