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

The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Gift this article