The OECD/G20 Inclusive Framework welcomed Guatemala as its newest member and reviewed progress on BEPS implementation, the Global Minimum Tax, and future international tax priorities at its 18th plenary meeting in Paris.
The OECD has issued a release following the 18th plenary meeting of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), held in Paris from 28 to 30 October 2026.
The meeting marked the 10th anniversary of the Inclusive Framework, which has grown from 82 to 148 members since 2016. Members welcomed Guatemala as the newest member of the Inclusive Framework, reflecting its continued expansion and global reach.
The Inclusive Framework is a platform enabling jurisdictions to work together on cross-border international tax matters to ensure a more coherent and stable international tax system that supports investment and growth.
The OECD also published an outcome statement, agreed by consensus among Inclusive Framework members, outlining the meeting’s key conclusions and next steps.
Statement by the OECD/G20 Inclusive Framework on BEPS (October 2026)
Executive overview and membership expansion
The OECD/G20 Inclusive Framework on BEPS held its 18th Plenary meeting from 28 to 30 October 2026 in Paris, France, with over 410 delegates from 131 jurisdictions and observers from 12 international organisations. Marking its 10th anniversary, the Inclusive Framework welcomed Guatemala as its newest member, bringing total membership to 148 jurisdictions, up from 82 in 2016.
Reflections on a decade of BEPS implementation
Members reviewed ten years of progress in implementing the BEPS minimum standards:
- Action 5: Eliminated more than 100 harmful preferential tax regimes and completed 64,000 exchanges of information on tax rulings.
- Action 6: Introduced anti-treaty abuse safeguards in over 95% of bilateral tax treaties.
- Action 13: More than 120 jurisdictions adopted Country-by-Country reporting.
- Action 14: Over 500 tax treaties were modified to strengthen Mutual Agreement Procedures (MAP).
Key milestones under the Pillar Two framework
Members highlighted progress on the Global Minimum Tax and the release of the Side-by-Side Package to coordinate eligible minimum tax regimes with GloBE Rules. They also noted progress on Amount B for baseline distribution activities and the Subject to Tax Rule (STTR), whose implementing multilateral convention is scheduled to enter into force in January 2027. Nearly 65 jurisdictions are expected to implement minimum tax regimes or qualify for Side-by-Side safe harbours by 2027.
Ongoing work programme and future priorities
- Global minimum tax implementation: Members reviewed the updated impact assessment and the interaction between minimum taxes and tax incentives. Technical work includes legislative reviews, development of the GloBE coordination mechanism, and assessments of existing regimes seeking Side-by-Side safe harbour qualification.
- Digitalisation of the economy: Members discussed tax challenges arising from digital business models and new technologies. The OECD Secretariat was asked to develop an action plan by the end of 2026 to promote coordinated international solutions, prevent double taxation, and protect tax bases.
- Cross-border worker mobility: Following a January 2026 public consultation, members approved the next phase of work to improve tax certainty, simplify compliance, and help tax administrations manage cross-border worker mobility.
- Tax policy, inequality, and growth: Members discussed capital taxation, business growth, and domestic resource mobilisation. A diagnostic report is expected at the next plenary in 2027.
Stakeholder collaboration and next steps
Members reaffirmed the importance of domestic resource mobilisation in strengthening tax capacity and promoting economic growth in developing countries. They also discussed tax policy responses to demographic changes and the use of artificial intelligence to reduce compliance costs and improve tax administration.
The Inclusive Framework will present its next major progress report at its plenary meeting in the first half of 2027.
