The OECD announced that 147 countries and jurisdictions participating in the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting have agreed key elements of a comprehensive package setting a course for the co-ordinated operation of global minimum tax arrangements through a “side by side” approach. The package comprises five elements: simplification measures intended to reduce calculation and reporting burdens for multinational enterprises and tax authorities; a new targeted substance-based tax incentive safe harbour aimed at further aligning the treatment of tax incentives; new safe harbours for multinational enterprise groups whose ultimate parent entity is located in an eligible jurisdiction meeting minimum taxation requirements; an evidence-based stocktake process to help maintain a level playing field among Inclusive Framework members; and reinforcement of qualified domestic minimum top-up tax regimes as a primary mechanism for protecting local tax bases, particularly in developing countries. Implementation tools and fact sheets are due in the coming weeks, and the OECD will host a dedicated webinar on 13 January 2026.
OECD 2026-01-05
OECD/G20 Inclusive Framework agrees side-by-side package to take forward global minimum tax arrangements
The Organisation for Economic Co-operation and Development (OECD) announced that 147 countries in the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting have agreed on key elements for global minimum tax arrangements, including simplification measures, substance-based tax incentive safe harbours, and reinforcement of domestic minimum top-up tax regimes. Implementation tools and fact sheets will be released soon, with a webinar on 13 January 2026.