Executive summary

On 16 April 2026, the Organisation for Economic Co-operation and Development (OECD) released its "Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors" (the Report), ahead of the G20 Finance Ministers and Central Bank Governors' (FMCBG)first 2026 meeting under the United States Presidency. Following the meeting, the Chair issued a Statement regarding the discussions, which does not include any reference to international tax matters.

The Report outlines recent developments in international tax projects and emphasizes the OECD's support for G20 tax initiatives. It includes an update on progress in implementing the Base Erosion and Profit Shifting (BEPS) minimum standards and the Global Minimum Tax (Pillar Two), as well as developments in tax transparency, tax certainty, tax administration modernization, capacity building for developing economies and other tax topics.

Detailed discussion

The OECD Secretary-General Tax Report to the G20 FMCBG provides an update on recent developments in international tax cooperation and expresses the OECD's commitment to working with the G20 to "advance efficient tax systems that support economic resilience, encourage investment and foster growth." The Report identifies the following priority areas for 2026:

• Supporting Global Minimum Tax implementation, including simplification, guidance and further coordination
• Fostering constructive dialogue on tax issues related to the digitalized economy
• Deepening tax transparency initiatives
• Advancing the tax-certainty agenda, with a focus on rule simplification, improved dispute prevention and effective dispute resolution
• Reducing tax obstacles from cross-border work patterns
• Strengthening tax policy design as countries balance fiscal pressures and long-term innovation and investment needs
• Expanding capacity-building for developing economies with a focus on ensuring that reforms can bolster domestic resource mobilization and economic growth potential
• Modernizing tax administration, including digital transformation to reduce compliance costs, improve performance, reduce tax gaps and support productivity

Global Minimum Tax (Pillar Two)

On Pillar Two, the Report describes the Global Minimum Tax framework as aiming to mitigate investment distortions and protect domestic tax bases, while improving certainty and stability for large cross-border businesses by ensuring that multinationals pay a minimum level of tax on their operations in each jurisdiction.

The Report notes that the adoption of the Side-by-Side package marks a significant technical and political achievement for the Inclusive Framework. It also provides an update on the planned work on Pillar Two, including further simplifications and guidance to tax administrations and in-scope companies. (For background, see EY Global Tax Alert, OECD releases Side-by-Side Package on Pillar Two Global Minimum Tax: Detailed review, dated 16 January 2026.)

The Report indicates that the Inclusive Framework will develop terms of reference and assessment methodologies for full legislative peer reviews to assess whether jurisdictions' domestic legislation provide outcomes consistent with the Global Anti-Base Erosion (GloBE) Model Rules, with these reviews expected to commence in the second half of 2026. In addition, the Report notes further work that is underway on updates to the GloBE Information Return and its XML schema to reflect the Side-by-Side package, as well as on expanding participation in the Multilateral Competent Authority Agreement on the Exchange of GloBE Information in time for first exchanges in December 2026.

The Report also indicates that further Administrative Guidance is under development in the Inclusive Framework, including a routine profits safe harbor and a de minimis simplification to take the place of those tests in the Transitional Country-by-Country Reporting Safe Harbour. It indicates that work will be done on integrity measures, which would be applicable under the Simplified Effective Tax Rate (ETR) Safe Harbour as well as more generally, and on guidance on conditional taxes and related benefits. Other discussion areas referenced in the Report include simplifications for investment entities and additional guidance on real estate investment vehicles, the substance-based income exclusion for mobile assets and issues raised by hyperinflationary currencies.

In parallel, the OECD Forum on Tax Administration is working to improve coordination and consistency in the administration of the Global Minimum Tax by bringing tax administrations together to share their practical experiences. According to the Report, this work will feed into a Global Minimum Tax Implementation Toolkit expected in 2026, developed with input from implementing tax administrations as well as business and other stakeholders.

Constructive dialogue on taxation of the digitalized economy

The Report notes that, as reflected in the April 2025 Inclusive Framework Plenary outcome statement, members have an interest in resuming discussions on tax challenges arising from the digitalization of the economy, following the conclusion of negotiations on the Side-by-Side agreement. According to the Report, members of the Inclusive Framework Steering Group have expressed a desire to return to that conversation and have acknowledged the importance of addressing the issues in a multilateral setting to avoid fragmentation and harmful unilateral measures. (For background, see EY Global Tax Alert, OECD/G20 Inclusive Framework issues statement following plenary meeting, dated 14 April 2025.)

The Report further indicates that, over the coming months, the OECD Secretariat will support the Inclusive Framework in reviewing the work done to date, gathering feedback on lessons learned and exploring how country priorities and ambitions have evolved, in order to chart the course for future discussions.

Global mobility of workers

The Report provides an update on work undertaken by the Inclusive Framework to evaluate the tax challenges associated with the global mobility of workers. According to the Report, this work has been in response to changes in how individuals and businesses work, including short-term remote working and business travel, cross-border commuting, expatriation and secondments and "digital nomads."

The Report notes that, since the project was launched in April 2025, the Inclusive Framework has gathered evidence on the scale and impact of these developments, drawing on input from tax policy and tax administration experts, existing research and a public consultation. This work has highlighted a range of questions regarding the application of existing domestic tax rules, tax treaties and tax administration frameworks, across corporate and personal income tax. Although some issues were addressed in the 2025 update to the OECD Model Tax Convention, the Report indicates that stakeholders have called for further work.

The Report indicates that the Inclusive Framework will evaluate these questions and explore areas where greater international coordination or knowledge sharing is needed. According to the Report, attention will continue to be paid to increasing tax certainty, exploring opportunities for simplification and streamlining compliance for taxpayers and tax administrations, while recognizing that the relevance and impact of global mobility issues may differ across countries and regions.

Other tax work

The Report briefly discusses the OECD's focus on evidence-based tax policy design analysis, including planned work agreed by the Inclusive Framework in April 2025 to examine links between tax policy, inequality and economic growth, beginning with the current diagnostic phase to gather evidence on country priorities and policy experiences. It also provides an update on the OECD's work on statistical publications and related analysis, including its "Revenue Statistics 2025" publication and the 2024 update of the OECD Investment Tax Incentives Database (released in March 2025).

The Report describes the OECD's work on tax treaties and transfer pricing standards as supporting economic growth and investment by reducing cross-border tax barriers, increasing predictability and certainty for businesses and ensuring consistent up-to-date international rules. It provides a brief overview of the latest update to the OECD Model Tax Convention, including changes addressing remote work, natural resource taxation and interpretative consistency. It also briefly describes the OECD's ongoing work on transfer pricing, including updating and modernizing guidance on intra-group services, supporting jurisdictions' implementation of Amount B for routine marketing and distribution activities, enhancing transparency through updated jurisdiction profiles and monitoring application of the Transfer Pricing Guidelines to improve tax certainty.

The Report also outlines efforts to modernize tax administration through digital transformation (Tax Administration 3.0), reduce compliance burdens and improve efficiency. It emphasizes tax certainty, pursued through focusing on simplification, dispute prevention (e.g., advance pricing arrangements) and dispute resolution mechanisms such as the Mutual Agreement Procedure and arbitration.

The Report reviews the OECD's ongoing tax and development work, focusing on supporting developing countries in strengthening domestic-resource mobilization and implementing international standards, including the Global Minimum Tax, as well as providing capacity-building through Tax Inspectors Without Borders and collaboration via the Platform for Collaboration on Tax.

In addition, the Report provides an update on progress in strengthening global tax transparency through the work of the Global Forum on Transparency and Exchange of Information for Tax Purposes. The Report notes the expansion of transparency efforts to information related to real estate through the publication of a new "Framework for the Automatic Exchange of Readily Available Information on Immovable Property." The Report also notes progress on transparency for crypto-assets through the Crypto-Asset Reporting Framework (CARF), indicating that 76 jurisdictions have committed to automatic exchange of crypto-asset information with the first exchanges expected to begin in 2027. Further work will focus on expanding participation, reinforcing confidentiality and data safeguards and supporting timely and effective implementation.

Annexes

The report also includes four Annexes providing more information on ongoing work.

Annex A - Status of BEPS minimum standards implementation: Annex A provides an overview of progress in implementing the BEPS minimum standards under Actions 5 (Harmful Tax Practices), 6 (Tax treaty abuse), 13 (Country-by-Country reporting) and 14 (Mutual Agreement Procedure). It highlights peer-review activity on harmful tax practices, growing adoption of treaty anti-abuse measures through the BEPS Multilateral Instrument, largely consistent implementation of Country-by-Country reporting with growing participation by developing countries and continued strengthening of dispute resolution through the Mutual Agreement Procedure, supported by enhanced transparency.

Annex B - Tax policy statistical updates: Annex B briefly discusses recent OECD tax statistics that show a slight increase in the average tax-to-GDP ratio across OECD countries in 2024, new information on the changing composition of personal income tax revenues and continued growth in tax revenues across African countries driven mainly by corporate income tax. It also provides an update on the OECD's database tracking trends in jurisdictions' energy and carbon taxation, including the broader deployment of emissions trading systems and policy adjustments being made in response to energy price hikes.

Annex C - Other tax and development activities: Annex C briefly outlines the OECD's ongoing tax-related capacity-building and outreach activities, including regional engagement on international tax developments, workshops on Amount B, expanded training through the OECD Academy, judicial tax capacity-building and technical work on the taxation of critical raw minerals.

Annex D - Progress on exchange of tax information peer reviews and capacity building: Annex D provides information on peer reviews of the implementation of tax transparency standards, with most jurisdictions rated compliant or largely compliant with respect to Exchange of Information on Request and continuing progress on implementation of Automatic Exchange of Information on Financial Accounts. It also references enhanced monitoring of peer-review recommendations, new annual monitoring of confidentiality and data safeguard assessments, increasing focus on emerging risks to tax transparency standards such as crypto-assets and artificial intelligence, and extensive capacity-building support.

Implications

The Report reinforces the need for companies to continue monitoring developments related to Pillar Two implementation, including forthcoming Administrative Guidance, peer review processes and information-exchange frameworks, and to consider the implications for compliance obligations and interaction with tax administrations across jurisdictions.

The Report also signals renewed discussion in the Inclusive Framework regarding tax challenges arising from the digitalization of the economy, although no specific timeline is identified. This is another area that bears watching.

Businesses should continue to track G20 and OECD tax-related discussions and assess their potential impact. They may also want to take the opportunity to participate in public consultations on tax proposals that would have implications for them and consider engaging with tax policymakers in relevant jurisdictions.