New International Agreement on Pillars 1 and 2

The OECD/G20 Inclusive Framework Reached a New Global Agreement on Profit Allocation and Minimum Tax Sullivan & Cromwell LLP - October 12, 2021

On October 8, 2021, 136 jurisdictions—almost all of the 140 working members of the OECD/G20 Inclusive Framework on Base Erosion and Profits Shifting (BEPS)—agreed to a statement on international tax reform. It updates the statement released in July and builds upon the Two-Pillar framework for the taxation of large multinational enterprises (MNEs). While many questions remain, key updates include the setting of a 15% global minimum rate and the addition of a new Annex featuring a detailed implementation schedule.