The G7’s side-by-side arrangement aims to limit corporate tax competition, protect government tax bases, and provide businesses with stable, predictable international tax frameworks.

The OECD Secretary-General issued a statement on 28 June 2025 regarding the G7’s agreement for a side-by-side arrangement exempting U.S. Parented Groups from Pillar 2’s Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR).

Statement by the OECD Secretary-General on G7 Progress on International Tax Co-operation

I warmly welcome today’s breakthrough statement by the G7, setting out a proposed way forward for the operation of global minimum tax arrangements.

The introduction of global minimum taxes in the US and through the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting represents a vital reform in international tax systems. This initiative is crucial for enhancing fairness and effectiveness in our increasingly digital and global economy.

The G7 statement on a side-by-side arrangement offers the opportunity to fulfill the original aim of establishing multilaterally agreed limitations on corporate tax competition and also safeguards the tax bases of governments. Moreover, any agreement along those lines would provide businesses worldwide with the certainty and stability they need in international tax frameworks.

I welcome the engagement now with the broader OECD Inclusive Framework regarding the proposed side-by-side arrangement.

Today’s statement by the G7 is an important milestone in international tax co-operation.

As multinational enterprises navigate the tax systems of various jurisdictions, the dialogue and collaboration fostered by the OECD becomes even more essential. International co-operation among sovereign nations enhances tax policy certainty, mitigates the risk of double taxation, and protects tax bases.

The OECD has led and facilitated multilateral tax policy discussions to improve our international tax arrangements for well over a decade. We will continue to work closely with all our Member and Partner countries through this important dialogue, to support increased trade, investment and growth.