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OECD report to G20 confirms delay to two-pillar tax deal implementation


Published: 19 Jul 2022 Update History

While the technical work on pillar two is close to completion, a deadline for signing a multilateral convention for the implementation of Amount A as part of pillar one has now been set for mid-2023 and expected to come into force in 2024.

The report by the OECD’s Secretary-General to G20 Finance Ministers and Central Bank Governors, published in July 2022, covers a number of developments in the tax arena. That includes an inclusive forum on carbon mitigation approaches and exchange of information agreements to improve international tax transparency.

Pillar two of the two-pillar international tax package is now ready for implementation by Inclusive Framework members. All of the G7, the EU, some of the G20 and other countries have already scheduled changes in their domestic legislation to introduce the model rules. Most have a planned entry into force in 2024. Some countries have also announced they will implement a domestic top-up tax, which is a way to help countries remove unnecessary tax incentives and eliminate profit shifting.

In relation to pillar one, negotiations are ongoing to turn the deal reached in October 2021 into practice, reallocating 25% of the profits of the world’s largest MNEs to market jurisdictions, regardless of whether they have a physical presence in those jurisdictions.

Rolling consultations have been launched over the course of 2022 relating to various building blocks of pillar one’s "Amount A". Progress has also been made on advancing the work on ‘Amount B’, to be delivered by the end of this year. Inclusive Framework members will now seek feedback from stakeholders on the overall design of the ‘Amount A’ rules, as well as the specific building blocks. The following timetable has been agreed for signing the multilateral convention (MLC) by mid-2023:

19 August 2022 Stakeholder feedback on the annexed Amount A progress report 
October 2022 The Inclusive Framework will review stakeholder input and seek to stabilise the rules at its meeting
First half of 2023 Work on the MLC to be completed and signed with the objective of enabling it to enter into force in 2024 once a critical mass of jurisdictions has ratified it.




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