OECD Issues Tax Report to G20 Finance Ministers, Central Bank Governors with Emphasis on Pillar Two Developments

Global Minimum Tax

In terms of Pillar Two developments, the report explicitly addresses the Side-by-Side package, released on 5 January 2026, which marks a significant technical and political milestone for the Inclusive Framework (for previous reporting, seeOECD Inclusive Framework Publishes Side-by-Side Package (5 January 2026)). The package intends to balance jurisdictional concerns with the core objectives of Pillar Two (for previous reporting, seeOECD Webinar Highlights Details of Side-by-Side Package (14 January 2026)). It delivers targeted simplifications, better alignment of substance-based incentives with real economic activity, accommodations for comparable minimum-tax regimes and strengthened risk-monitoring commitments. Alongside the release of the Side-by-Side package, the Central Record for Global Minimum Tax purposes was updated in January 2026 and now lists 44 Qualified Income Inclusion Rule regimes and 46 Qualified Domestic Minimum Top-up Tax regimes. Additionally, the US regime has been added to the Record as a Qualified Side-by-Side regime.

With respect to potential future developments, further simplifications and guidance will follow through an ongoing work programme. In addition, peer reviews, transitional self-certification and full legislative reviews will begin from the second half of 2026, following the development of terms of reference and assessment methodology by the Inclusive Framework (IF). Updates to the GloBE Information Return and XML schema are underway, alongside expanded participation in the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) to enable first exchanges in December 2026, the report highlights. Furthermore, additional administrative guidance is being developed on safe harbours, de minimis rules, investment entities, integrity measures, conditional taxes and sector-specific and technical issues.

Finally, the report notes that members of the Steering Group of the IF have expressed a common desire to continue discussions on the tax challenges of the digital economy.

Tax Treaties and Transfer Pricing

The report highlights the update to the OECD Model Convention to include, among other items, guidance on remote working and a new alternative provision for natural resources (for previous reporting, seeOECD Publishes 2025 Update to 2017 OECD Model Tax Convention (19 November 2025)).

In the field of transfer pricing, the OECD work focused on updating the guidance on intra-group services, with a view to publishing a consultation document to gather stakeholder input and on supporting jurisdictions in the implementation of Amount B.

Other Developments

In terms of other tax developments highlighted in the report, OECD continues to support reducing uncertainty, preventing double taxation, curbing base erosion and profit shifting and protecting tax bases. The ten-year BEPS implementation stocktake presented to the G20 in October 2025 highlights substantial progress in addressing harmful tax practices and stabilizing revenues across both developed and developing economies. At the same time, enhanced tax transparency remains a key priority on the OECD's agenda, including the continued development of the automatic exchange of information framework, new initiatives covering real estate data and measures addressing emerging risks such as crypto assets. The report notes that the OECD continues to support the modernization of tax systems, the improvement of compliance and capacity building for developing economies.

The report, published on 16 April 2026, is accessible here.