Summary

On 5 January 2026, the Organisation for Economic Co‑operation and Development (OECD) published a press release reporting that the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) agreed on the components of a “side‑by‑side” package intended to support the coordinated operation of the Pillar Two global minimum tax arrangements. The agreed package outlines simplification measures, safe harbours, alignment of tax incentive treatment, mechanisms for monitoring implementation, and reinforcement of qualified domestic minimum top‑up tax regimes.

Key points

Inclusive Framework Agreement

The OECD press release states that 147 countries and jurisdictions participating in the OECD/G20 Inclusive Framework on BEPS have agreed on the key elements of a comprehensive side‑by‑side package that charts a way forward for the coordinated operation of global minimum tax arrangements under Pillar Two.

Simplification Measures

The package includes a series of simplification measures that will reduce compliance burdens for multinational enterprises (MNEs) and tax authorities in relation to the calculation and reporting obligations under the Pillar Two global minimum tax rules.

Alignment of Tax Incentive Treatment

The package aligns the treatment of tax incentives globally by introducing a new targeted substance‑based tax incentive safe harbour.

New Safe Harbours

The OECD press release specifies that the package provides new safe harbours that are available to MNE groups with an ultimate parent entity located in an eligible jurisdiction that meets minimum taxation requirements.

Monitoring and Stocktake Process

The agreed package introduces an evidence‑based stocktake process to support maintenance of a level playing field for all members of the Inclusive Framework.

Qualified Domestic Minimum Top‑Up Tax Regimes

The package reinforces that qualified domestic minimum top‑up tax (QDMTT) regimes remain a primary mechanism within the global minimum tax framework for protecting local tax bases, especially in developing countries.

Source

Organisation for Economic Co‑operation and Development (OECD), International community agrees way forward on global minimum tax package (5 January 2026)

https://www.oecd.org/en/about/news/press‑releases/2025/12/international‑community‑agrees‑way‑forward‑on‑global‑minimum‑tax‑package.html

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This content is for general informational purposes only and does not constitute professional advice.

Information provided herein is based on publicly available sources as of the publication date and may be subject to change.

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