Opinion: G20 plays safe on tax reform as BEPS marks 10 years

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Opinion: G20 plays safe on tax reform as BEPS marks 10 years

New Delhi backdrop 2000x.jpg
New Delhi, where G20 leaders gathered in September

Another G20 summit, another anodyne few words in the post-meeting statement about support for international tax reform, says Ralph Cunningham.

Nothing in the 317 words about international tax in the 37-page Leaders’ Declaration, following the heads of government gathering in New Delhi this weekend, would have surprised any tax director or adviser. The section was in response to the OECD secretary-general’s report to the summit on the organisation’s tax work, which updated leaders on topics such as the two-pillar strategy, transparency, crime and climate change.

The leaders said that they “reaffirm our commitment to continue cooperation towards a globally fair, sustainable and modern international tax system appropriate to the needs of the 21st century” and “remain committed to the swift implementation of the two-pillar international tax package”.

They noted the “significant progress” on pillar one including on the text of a multilateral convention (MLC), which they want to be signed this year, and the work on amount B – how the arm’s-length principle will be applied to in-country baseline marketing and distribution activities – as well as the completion of the work on the development of the subject to tax rule under pillar two.

As well as looking for the MLC to be signed by the end of 2023, the governments called on negotiators to complete the work on amount B according to the same timeline.

GloBE rulemaking

The statement also mentioned approvingly how national governments were implementing the global anti-base erosion rules and a plan to offer additional help and technical assistance to developing countries.

BEPS 2.0 was not the only international tax topic to get a mention from the G20 leaders. They also called for the “swift implementation” of the CryptoAsset Reporting Framework (CARF) and amendments to the Common Reporting Standard, which the OECD unveiled in October 2022. This initiative enables the annual automatic exchange of tax information between the jurisdictions of taxpayers that hold crypto-assets or participate in crypto-asset transactions.

Heads of government also want the Global Forum on Transparency and Exchange of Information for Tax Purposes to keep it updated on the work to get CARF exchanges up and running in the countries that want this facility by 2027.

Of course, this was a meeting of G20 heads of government, none of whom are intimately involved in the negotiations, so you would not expect the section on international tax reform to discuss the technicalities. These post-G20 summit statements would certainly cause a stir if they questioned the detail of what their tax administrators were dealing with.

After all, it was the G20, at the OECD’s prompting, which set the existing international tax reform process in September 2013 by calling on OECD member countries to deliver on an “ambitious and comprehensive plan to restore confidence in the international tax system and ensure that profits are taxed where economic activities and value creation is realised”.

In any case, the nature of post-international summit statements is that they are the subject of negotiation between officials for days, if not weeks, before the event takes place. Governments will already have had some time to digest what their international tax negotiators have been up to.

more across site & shared bottom lb ros

More from across our site

Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
From Instagram content to £100m transactions, the founder of Thomas & Co International discusses building a modern tax and accounting firm for business founders
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Pillar two has been clients’ ‘biggest headache’ but also a driver of growth for MHA, which believes it has the edge over its big four rivals
Public country-by-country reporting is exposing multinational tax data to investors, journalists and competitors, creating fresh risks for businesses
Gift this article