A Regional Perspective on Global Tax Reform

On Friday 8 October 2021, after years of negotiations, the OECD announced that 136 countries had reached agreement on a sweeping overhaul of the international tax system that will impose a 15% minimum tax rate on some multinational enterprises (MNEs) and reallocate more than USD 125 billion of profits from approximately 100 of the world’s largest and most profitable MNEs to countries worldwide. The OECD released an eight-page statement that updates its July 1 blueprint and includes an annex that provides important details regarding implementation of the agreement. The new statement follows the outline of the original plan: a two-pronged framework, with Pillar One addressing taxing rights and distribution of profits and Pillar Two the imposition of a global minimum tax. In this short report from BDO, we reflect on some of the implementation challenges globally and from a regional perspective.

BDO’s Global Tax Alert ‘Global Tax: OECD announcement of agreement on International Tax Reform’, 9 October 2021, provides a useful summary of the key features of the agreement and of those points which have been clarified since the initial announcements of July 2021.

Numerous publications attempt to tackle the many open questions that remain and the challenges of implementation. Few of these efforts however have focused on a comparative review of the attitudes toward these proposals in the countries participating in the exercise. In this short report from BDO, we provide such a regional perspective – a broad indicator into the views expressed by governments and leading commentators, in a number of local markets. It is based on responses to questions asked of BDO Tax partners from across the globe, in anticipation of and in response to the OECD announcement.

Although the OECD has since finalized the framework, this summary provides important insights into the attitudes to this global tax agreement across a range of jurisdictions – attitudes that can be expected to influence how the deal is implemented (and perhaps even evolves) in the coming years. We plan to take a further look at implementation – how the proposals are in practice being implemented across jurisdictions, as the months unfold. Look out for future BDO insights in this series.

This article follows BDO’s opinion piece of 28 July, G-20 backs G-7 support for global minimum tax and new allocation rules – what’s the real impact? in which we presented many of the unresolved details, both technical and policy-related, to be overcome before global agreement is reached. Readers of this article can also refer to BDO’s interactive Taxation of the Digital Economy tool for an update on the range of unilateral measures – including new digital taxes - being introduced around the world, while countries continue to take matters into their own hands.