The Organisation for Economic Co-operation and Development (OECD) has released the OECD Secretary-General Tax Report (G20 Brazil, October 2024), which was presented to the G20 Finance Ministers and Central Bank Governors at their meeting in Washington, DC, US, from 23 -24 October  2024.

This report sets out recent developments in international tax reform since July 2024, including on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy. It also covers progress made on the implementation of the BEPS minimum standards and tax transparency, as well as updates on tax policy, tax and inequality and tax administration.

OECD Secretary-General reported 57 jurisdictions gathered in Paris on 19 September to support the signing ceremony of a new multilateral treaty to implement the Subject to Tax Rule (STTR), further strengthening global minimum taxation and providing developing countries with a more straightforward tool to help ensure they receive their fair share of tax revenue.

The STTR taxes any such payments when they are undertaxed in the recipient’s jurisdiction, helping to protect their tax base. More than 70 developing country members of the G20/OECD Inclusive Framework on BEPS (Inclusive Framework) are eligible to request inclusion of the STTR in their agreements with other members of the Inclusive Framework in accordance with the commitment on the STTR, either through the bilateral amendments to tax agreements or the new multilateral treaty (STTR MLI).

The STTR MLI was approved by the Inclusive Framework in September 2023 and 19 Inclusive Framework members signed the MLI (or a letter of intention to sign the MLI as soon as possible) on 19 September 2024.

The STTR complements other efforts to raise the floor on the international taxation of corporate revenues. The recent publication of provisional legislation by Brazil and the recent enactment of legislation by Bahrain and Turkey, brings to 45 the current number of jurisdictions that have already enacted or introduced legislation to implement the global minimum tax under the Global Anti-Base Erosion (GloBE) Rules.  A further 16 jurisdictions have taken concrete steps toward implementation.