The OECD has released the OECD Secretary-General Tax Report to G20 Leaders, prepared for the G20 Leaders’ Summit taking place on 18-19 November 2024, in Rio de Janeiro, Brazil.

This report sets out recent developments in international tax reform, 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.

This latest report follows the OECD Secretary-General’s tax report to the G20 finance ministers and central bank governors in October 2024. This report covered similar topics as discussed in the G20 leaders report, but it mainly highlighted developments since July 2024.

The details of the tax report are as follows:

In a significant development, 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. Developing countries are often the source of significant outbound payments that can be subject to low or no taxation.

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 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. As of October 2024, the recent publication of provisional legislation by Brazil, and the recent enactment of legislation by Bahrain and Türkiye, 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. The OECD Secretary-General looks forward to continuing this important work together to stabilise the global tax landscape, curb harmful tax competition and help generate important additional revenues for governments around the world.

The global minimum tax builds on the foundations of the original project to address base erosion and profit shifting (BEPS Project).

As we approach the ten-year anniversary of the launch of the BEPS 2015 Final Reports, the Inclusive Framework will take stock of the BEPS Project and look to the future. At the next Plenary meeting of the Inclusive Framework, to take place in April 2025, members will reflect on a future agenda and pick up on the important discussions undertaken throughout 2024 on ensuring inclusiveness and stakeholder participation at the Inclusive Framework.

The OECD Secretary-General looks forward to reporting to you on these developments during the South African Presidency in 2025, as well as on the follow up to the G20 Finance Ministers’ and Central Bank Governors’ encouragement to the Inclusive Framework to consider work on inequality in the context of effective progressive tax policies.