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

As ITR data reveals that 2025 saw more than double the amount of private client hires than 2024, it seems firms are jostling for position
The US multinational paid 20% more tax in 2025 than 2024, it said; in other news, more than 25,000 HMRC staff have been upskilled on AI
Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning
The acquisition of a two-partner practice from Stephenson Harwood means that Charles Russell Speechlys has the largest private client team in Asia, the firm claimed
Complex and constantly shifting rules on global mobility mean ‘the risk is too great’ for staff to work abroad on personal time, EY’s Maureen Flood tells ITR
While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
Gift this article