Over 145 countries and jurisdictions working together within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) have agreed on key elements of a package that charts a course forward for the co-ordinated operation of global minimum tax arrangements in the context of a digitalised and globalised economy.
Following months of intense negotiations, the comprehensive package for a "side by side" arrangement announced today represents a significant political and technical agreement which will set the foundation for stability and certainty in the international tax system. It will preserve the gains achieved so far in the global minimum tax framework and protect the ability for all jurisdictions, particularly developing countries, to have first taxing rights over income generated in their jurisdictions.
The package includes five key components:
- First, a series of simplification measures will reduce compliance burdens for multinational enterprises (MNEs) and tax authorities in calculating and reporting under the global minimum tax rules.
- Second, the package further aligns the treatment of tax incentives globally through the introduction of a new targeted substance-based tax incentive safe harbour.
- Third, new safe harbours are available to MNE Groups having an ultimate parent entity located in an eligible jurisdiction which meets minimum taxation requirements.
- Fourth, the package includes an evidence-based stocktake process to ensure a level playing field is maintained for all Inclusive Framework Members.
- Fifth, the package reinforces the objective that qualified domestic minimum top-up tax regimes remain a primary mechanism in the global minimum tax framework for ensuring the protection of local tax bases, particularly in developing countries.
"This agreement by the Inclusive Framework including more than 145 countries is a landmark decision in international tax co-operation," OECD Secretary-General Mathias Cormann said. "The Members of the Inclusive Framework are to be commended for their work in finalising this package, which enhances tax certainty, reduces complexity, and protects tax bases. I look forward to seeing the Inclusive Framework take forward the implementation of this package, as well as to future proposals for further simplifications of the global minimum tax rules and compliance burdens."
Additional tools and fact sheets to support implementation of the package will be made available in the coming weeks, alongside a dedicated webinar hosted by the OECD on 13 January 2026. The OECD will also continue to ensure that the rules can be implemented effectively and efficiently by all countries and jurisdictions, offering comprehensive capacity-building assistance where needed.
To access the comprehensive package, please visit: https://www.oecd.org/en/topics/sub-issues/global-minimum-tax/global-anti-base-erosion-model-rules-pillar-two.html
To register to the webinar, please visit: https://www.oecd.org/content/oecd/en/events/2026/01/global-minimum-tax-understanding-the-side-by-side-package.html
