英文_OECD_经合组织秘书长向G20财长和央行行长提交的税务报告（G20南非_2025年7月）_25页_1mb

报告摘要

OECD Tax Report Summary to G20 Finance Ministers and Central Bank Governors (G20 South Africa, July 2025)

Introduction

This report summarizes key developments in international taxation since the last report in February 2025. It highlights progress on G20 initiatives, including the Inclusive Framework's Annual Plenary Meeting, the implementation of the Two-Pillar International Tax Package, and advancements in tax transparency and cooperation. The OECD provides evidence-based policy analysis and supports members in addressing global tax challenges.

Support for G20 Initiatives

Provided data-driven policy research and specific responses to the South African presidency.
Agreed on a phased approach to examine tax policy's interaction with inequality and growth, aiming to inform future discussions.
Conducted a stocktake on BEPS progress since 2010, identifying opportunities for optimization in resource allocation and international cooperation.
Supported tax transparency standards, noting a significant reduction in the offshore tax gap and progress in automatic information exchange.
Plans simplification measures to reduce compliance costs for taxpayers and tax administrations, with reports to be delivered ahead of the October meeting.

Inclusive Framework Plenary Meeting (April 2025)

Nearly 450 delegates from 135 countries met to discuss international tax reforms.
Key outcomes included prioritizing tax certainty, agreeing to explore new areas like global mobility and inequality, and improving governance processes.
DECISIONS to phase studies on tax, inequality, and growth, as well as global mobility, using evidence-based approaches.
The meeting underscored the importance of the Two-Pillar Solution for stability in the international tax system.

Two-Pillar International Tax Package

Pillar One

Amount A: Introduces coordinated allocation of taxing rights for residual profits of large MNEs, enhancing tax certainty and preventing double taxation. Focuses on digital economy challenges.
Amount B: Provides a streamlined transfer pricing approach for market-related activities, published as a consolidated resource for administrations and taxpayers. Several countries are implementing this.

Pillar Two

Subject-to-Tax Rule (STTR): Allows jurisdictions to tax certain income with effective rates below 9%, integrated into treaties. Over 70 developing countries are eligible to request its inclusion.
Global Minimum Tax (GloBE Rules): Aims to mitigate base erosion, enforces a minimum tax rate. More than 55 jurisdictions have implemented or plan to implement it; a central record tracks qualified legislation.
Simplification efforts to reduce compliance burdens, including tools for MNEs, following concerns from the US and G7.

Implementation of Base Erosion and Profit Shifting (BEPS) Minimum Standards

Action 5 (Harmful tax practices): Peer reviews and exchanges of rulings increased significantly, with most regimes aligning with standards; 11 nominal-tax jurisdictions introduced substance requirements.
Action 6 (Tax treaty abuse): Rapid uptake of the BEPS Multilateral Instrument; over 90% of treaties comply, with continuous monitoring and assistance.
Actions 13 and 14 (CbC Reporting and MAP): Widespread implementation of country-by-country reports; progress in mutual agreement procedures, with recommendations for simplification and reporting.
Burden reduction measures: Peer reviews streamlined, and support tailored for developing countries to ease implementation.

Tax, Inequality, and Growth

Inclusive Framework agreed to initiate a workstream on tax's role in inequality and growth, built on previous discussions and G20 interest.
The phased, analytical approach will gather evidence, facilitate policy exchanges, and inform domestic and international responses while respecting tax sovereignty.

Global Mobility

New workstream launched to address tax challenges from cross-border and remote work, focusing on reducing barriers and risks to tax bases.

Tax Policy and Statistics

Includes regional analyses, such as Latin America (21.3% tax-to-GDP ratio, slight decline) and Asia-Pacific (steady increase in tax revenues).
Publications on topics include capital gains taxation, corporate tax influence on green investments, and corporate function allocation studies.

Tax and Development

OECD organized virtual events, workshops, and training (e.g., on the Global Minimum Tax for African countries), supporting capacity building in developing regions.
Toolkits for extractive sector taxation being developed; programs like "Tax Inspectors Without Borders" have significantly increased revenues and compliance.
Independent evaluation of development programs rated them highly effective, with strong stakeholder feedback.

Global Forum on Transparency and Exchange of Information for Tax Purposes

Continues peer reviews, capacity building, and implementation of standards like the Crypto-Asset Reporting Framework (CARF).
Notable entries: Bolivia joined as Global Forum member in June 2025; additional jurisdictions committed to CARF.
Revenue impact: Major findings in Asia and Latin America highlight billions in additional annual revenues from transparency measures.