Two-pillar solution will lead to more tax revenues, says OECD

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

Two-pillar solution will lead to more tax revenues, says OECD

Viersen, Germany - January 9. 2022: Closeup of mobile phone with

The solution to address the tax challenges arising from digitalisation and globalisation will generate more revenue than previously estimated.

The OECD Secretariat presented its updated economic analysis of the impact on tax revenue based on the latest estimates for pillars one and two, during a webinar yesterday, January 18.

It found that the increase in tax revenue from pillar two’s global minimum corporate tax rate is now expected to be about $220 billion annually (9% of global corporate tax revenues). This is based on 2018 data and compares with $150 billion a year in the previous estimate, which was published in 2020.

Pillar one – fairer distribution of taxing rights among jurisdictions over the largest and most profitable companies – is now expected to affect the allocation of about $200 billion in profits, based on data from 2021. This amounts to global annual tax revenues of $13 billion to $36 billion a year. It is a significant increase on the 2020 estimate of $125 billion.

About 50% of the profits under pillar one will come from large digital companies, such as electronics manufacturers and internet businesses.

For pillar one, the OECD has also compiled data on jurisdictional impact. This shows that, on average, low- and middle-income jurisdictions are likely to be allocated new taxing rights and will therefore gain the most. Investment hubs will face greater revenue losses, as they are likely to surrender more taxing rights than they are allocated.

The changes from the 2020 estimate are mainly due to design changes to both pillars, more recent and better data (including increased country coverage and reporting) and some changes in modelling.

David Bradbury, deputy director of the OECD Centre for Tax Policy and Administration based in Paris, said that the research shows that governments (particularly in developing countries) will benefit from implementing the two-pillar solution.

“I do believe this study stands head and shoulders above others that have been released to this point,” added Bradbury, saying: “What we model is very closely aligned to what has been agreed thus far.”

More than 135 countries and jurisdictions agreed the two-pillar solution in October 2021, which aims to ensure a fairer distribution of taxing rights among jurisdictions over the largest and most profitable multinational enterprises, and put a floor on tax competition by creating a global 15% minimum effective corporate tax rate.

In particular, the OECD believes the reform will stabilise the international tax system, enhance tax certainty and avert the proliferation of unilateral digital services taxes and associated tax and trade disputes, which could reduce global GDP by up to 1% annually.

In December 2022, the EU agreed to move forward with the implementation of the global minimum tax. Pillar two has also featured in budgets in the UK and Canada, while South Korea is moving ahead with its legislation. Numerous other countries have said they plan to implement it.

The text for a multilateral convention on pillar one will be opened for signature by the middle of this year.

The OECD webinar is available online and a full economic analysis and detailed methodology are expected to be published soon.

more across site & shared bottom lb ros

More from across our site

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
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
Gift this article