REVENUE gains from the implementation of a historic agreement to reform the international tax system will be higher than previously expected, according to new OECD analysis released today.

The two-pillar solution to address the tax challenges arising from the digitalisation and globalisation of the economy will lead to additional taxing rights for market jurisdictions and put a floor on tax competition through the creation of a global 15% minimum effective corporate income tax rate.

The proposed global minimum tax is now expected to result in annual global revenue gains of around USD 220 billion, or 9% of global corporate income tax revenues. This is a significant increase over the OECD’s previous estimate of USD 150 billion in additional annual tax revenues attributed to the minimum tax component of Pillar Two.

Pillar One, designed to ensure a fairer distribution of taxing rights among jurisdictions over the largest and most profitable multinational enterprises (MNEs) is now expected to allocate taxing rights on about USD 200 billion in profits to market jurisdictions annually. This is expected to lead to annual global tax revenue gains of between USD 13-36 billion, based on 2021 data. 

The new estimates reflect a significant increase compared to the USD 125 billion of profits in previous estimates. The analysis finds that low and middle-income countries are expected to gain the most as a share of existing corporate income tax revenues. 

“The international community has made significant progress towards the implementation of these reforms, which are designed to make our international tax arrangements fairer and work better in a digitalised, globalised world economy,” OECD Secretary-General Mathias Cormann said. “This new economic impact analysis again underlines the importance of a swift, efficient and widespread implementation of these reforms to ensure these significant potential revenue gains can be realised. Widespread implementation will also help stabilise the international tax system, enhance tax certainty and avert the proliferation of unilateral digital services taxes and associated tax and trade disputes, which would be bad for the global economy and economies around the world.”

The new estimates on the economic impact of the two-pillar solution are based on updated data and incorporate most of the recently agreed design features included in the Amount A Progress Report and the GloBE Model Rules, many of which have not been accounted for in other studies. 

The update to the OECD’s earlier assessments, including its detailed Economic Impact Assessment issued inOctober 2020, shows that projected revenue gains under Pillar One have increased, and continue to rise over time, due to both revisions to the design of the tax reform and increased profitability of in-scope MNEs. It also shows increased projected revenue gains from Pillar Two, which reflects some increases in global low-taxed profit, including as a result of improved data coverage. 

The analysis highlights that several design features included in the recent Amount A Progress Report would have particularly beneficial impacts for small and low-income countries.