OECD: 147 Countries Agree to 15% Global Minimum Corporate Tax with Exemption for US Companies
The Organisation for Economic Co-operation and Development (OECD) recently announced that 147 countries and jurisdictions have reached an agreement to formally advance the implementation of a 15% global minimum corporate tax on multinational enterprises. The agreement aims to ensure large multinational companies pay their fair share of tax where they operate, preventing the shifting of profits to low-tax jurisdictions. This agreement includes the establishment of an exemption mechanism for US-headquartered companies to maintain the stability of international tax cooperation.
This arrangement stems from the 2025 G7 negotiations and was influenced by the US government’s position. Other countries agreed to this mechanism in exchange for the continued participation of the United States in the Inclusive Framework.
Background and Core Content of the Agreement
Negotiations for the global minimum corporate tax plan began in October 2021, promoted by the OECD/G20 Inclusive Framework. The agreement primarily targets multinational enterprises with annual revenues exceeding a certain threshold, introducing standardized tax collection mechanisms and income allocation rules to ensure companies pay taxes in the countries where they conduct activities.
The agreement also includes measures to simplify calculations and reporting to reduce compliance costs for businesses, while protecting the tax base of developing countries. The OECD has described this as a “historic decision” that will enhance the security and stability of the international tax system.
Details of the Exemption for US Companies
To address the risk of a potential US withdrawal from the agreement, the 147 members agreed to provide an exemption for US-headquartered multinational corporations. This mechanism allows the US to maintain its existing tax system on foreign income, preventing a potential loss of over $100 billion for US taxpayers.
This compromise originated from the G7 talks in June 2025, after which the US Treasury Department confirmed that the arrangement would not apply to certain Pillar Two rules. Several international media outlets reported that this move reshapes the original 2021 agreement, ensuring that US companies are exempt from certain foreign top-up taxes.
Impact on National Tax Environments
Several countries have already initiated related legislation. In June 2024, Spain approved the EU Directive to implement a 15% minimum tax on multinational companies with annual revenues exceeding €750 million, covering 126 domestic companies and 707 foreign-owned groups.
French Finance Minister Bruno Le Maire stated that the agreement will cover large digital groups, ensuring they pay taxes where they do business. It is estimated that this could increase France’s annual tax revenue by €5 billion to €10 billion. Other EU member states are also advancing similar measures to create a unified approach to the problem of profit shifting.
Significance of International Tax Cooperation
This agreement is considered a significant advancement in global tax governance. Despite the introduction of the US exemption, the core 15% minimum tax rate still applies to the vast majority of multinational enterprises. The OECD emphasizes that this arrangement helps to preserve long-term multilateral cooperation and avoids conflicts that could arise from unilateral tax measures.
Future implementation will depend on the legislative progress in each country and is expected to gradually change the global corporate tax landscape.
