Executive summary

At the conclusion of the 28-29 February 2024 meeting of the G20 Finance Ministers and Central Bank Governors, the Chair issued a meeting summary underscoring the importance of enhanced international economic cooperation and reiterating the G20's focus on finalizing the Base Erosion and Profit Shifting (BEPS) 2.0 project.

Before the G20 meeting, the Organisation for Economic Co-operation and Development (OECD) had released the Secretary-General Tax Report to the G20 Finance Ministers and Central Bank Governors, providing an update on international tax matters including progress on the BEPS 2.0 project, implementation of the minimum standards of the original BEPS project, tax development and tax transparency.

Detailed discussion

G20 Chair's summary

The first meeting of the G20 Finance Ministers and Central Bank Governors under the Brazilian G20 presidency was held in São Paulo, Brazil on 28-29 February 2024. The Brazilian Chair issued a brief summary at the conclusion of the meeting. On international taxation, the summary indicates that the Finance Ministers will focus on "finalizing the two-pillar solution, including reaching a timely agreement on the Pillar 1 Multilateral Convention with a view to signing by end-June 2024 and continue to foster global dialogue on fair and progressive taxation."

The Annexes to the Chair's meeting summary include a list of the key priorities proposed by the Brazilian G20 presidency for each of the G20 workstreams. The priorities for international taxation are:

• Devising tax strategies as instruments to reduce inequality
• Continuing the work on the two-pillar international tax package following the timeline agreed to by the OECD/G20 Inclusive Framework
• Enhancing tax transparency, including transparency on beneficial ownership
• Studying the intelligent and effective use of tax benefits

Also listed in the Annexes are three reports on international taxation received by the G20:

1. The OECD Secretary-General Tax Report
2. The report of the UN Secretary-General on Promotion of Inclusive and Effective International Tax Cooperation at the United Nations
3. The EU Tax Observatory's Global Tax Evasion Report 2024

OECD Secretary-General Tax Report

The February 2024 Secretary-General Tax Report provides an update on the ongoing work on international taxation. On Pillar Two of the BEPS 2.0 project, the Report indicates that the global minimum tax has been or will be implemented by more than 35 jurisdictions with effect in 2024. Also on Pillar Two, the Report notes that more than 70 developing countries in the Inclusive Framework are entitled to request inclusion of the subject-to-tax rule (STTR) in their treaties with Inclusive Framework members.

On Pillar One, the Secretary-General Tax Report states that the Inclusive Framework is working toward finalizing the text of the multilateral convention (MLC) on Amount A by the end of March 2024 with a view of holding a signing ceremony by the end of June 2024. It also indicates that the Amount B report was approved by the Inclusive Framework and released in February 2024 and has been incorporated into the OECD Transfer Pricing Guidelines. The Report further notes that additional work related to Amount B is ongoing, including work on the interdependence of Amount B and Amount A that will be undertaken prior to the signing and entry into force of the MLC.

In addition, the Secretary-General Report provides an update on the work around inequality and progressivity of tax systems, noting that OECD analysis suggests there is considerable scope to enhance the design and effectiveness of taxes on capital to raise more revenue and reduce inequality. The Report indicates that the OECD intends to release two papers in 2024 focusing on the taxation of capital gains and closely held businesses. The Report also notes the need for further work in this area, including potential work to identify challenges involved in taxing high-net-worth individuals in a globalized economy.

The Secretary-General Tax Report provides a status update on jurisdictions' implementation of the minimum standards established in the original BEPS project, relating to Actions 5 (harmful tax practices), 6 (tax treaty abuse), 13 (country-by-country reporting) and 14 (mutual agreement procedure). It also contains an update on the activity of the Global Forum on Transparency and Exchange of Information for Tax Purposes, as well as brief discussions of ongoing work in the areas of tax and development, tax and crime, and indirect tax.

Implications

The G20 Finance Ministers' continued focus on finalizing the BEPS 2.0 project underscores the political interest in Pillars One and Two. This year will be a pivotal year for both pillars. It is important for companies to follow developments in the global negotiations and monitor implementation activities in all countries that are relevant to their businesses.