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）_26页_2mb

OECD Secretary-General Tax Report Summary to G20 Finance Ministers and Central Bank Governors

Introduction

This report outlines key developments in international tax policy since the last report in February 2025, in preparation for the third G20 Finance Ministers' and Central Bank Governors' meeting under the South African Presidency. It highlights the progress made in implementing the BEPS minimum standards, the ongoing work on the Two-Pillar International Tax Package, and the OECD's efforts to support developing countries in tax policy and administration.

Core Content

• G20/OECD Inclusive Framework on BEPS held its 17th annual plenary meeting in April 2025 in Cape Town, South Africa, with over 450 delegates.
• The meeting focused on:
  • Reducing compliance burdens for countries implementing BEPS minimum standards.
  • Introducing two new workstreams: global mobility and the interaction between tax policy, inequality, and growth.
  • Continuing discussions on the Two-Pillar Solution to ensure stability and certainty in the international tax system.
• The OECD, in consultation with the Global Forum, prepared a stocktake report on tax transparency progress since the G20's inception (Annex A), showing significant improvements in information exchange and reducing the offshore tax gap by nearly 70% over the past decade.

Key Views and Developments

Two-Pillar International Tax Package

Pillar One: Coordinated Allocation of Taxing Rights

• Amount A introduces a coordinated system to allocate taxing rights to market jurisdictions for a portion of the residual profits of large MNEs, aiming to improve tax certainty and avoid double taxation.
• Amount B provides a simplified transfer pricing approach for marketing and distribution activities, enhancing clarity and reducing compliance burdens for MNEs.

Pillar Two: Global Minimum Tax

• Pillar Two includes:
  • Subject-to-Tax Rule (STTR): Allows jurisdictions to "tax back" income taxed at rates below the 9% minimum rate, if it has been ceded under a treaty.
  • Global Minimum Tax (GloBE Rules): Aims to mitigate investment distortions and protect domestic tax bases, with over 55 jurisdictions implementing or planning to implement the rules by 2025.
• The OECD has released a central record of legislation for qualified minimum tax regimes, now including 29 Qualified Income Inclusion Rules and 30 Qualified Domestic Minimum Top-up Taxes as of March 2025.
• The GloBE Information Return (GIR) is being implemented through the Multilateral Competent Authority Agreement (GIR MCAA), enabling central filing by MNE Groups.

Implementation of BEPS Minimum Standards

Action 5 – Harmful Tax Practices

• Peer reviews of over 130 jurisdictions have been conducted annually.
• Over 58,000 exchanges of tax rulings have occurred, and 332 regimes have been reviewed.
• Almost all regimes are now aligned with the standard, with over 40% abolished.

Action 6 – Tax Treaty Abuse

• The BEPS MLI has been implemented in over 1,960 bilateral tax treaties, modifying more than 1,500 of them.
• 105 jurisdictions are signatories, with 89 having ratified the agreement.
• Over 90% of Inclusive Framework tax treaties are compliant with the minimum standard.

Action 13 – Country-by-Country Reporting (CbC)

• Over 120 Inclusive Framework members have introduced legislation requiring CbC reports from MNEs over EUR 750 million.
• More than 4,600 bilateral relationships for automatic exchange of CbC reports have been established.
• 81 members have completed the necessary building blocks to receive CbC reports.
• A simplified peer review process is being implemented for developing countries, allowing them to set their own timelines for accessing CbC reports.

Action 14 – Mutual Agreement Procedure (MAP)

• Peer reviews have been conducted for 82 jurisdictions, with reports for six already published.
• 76 jurisdictions with limited or no MAP experience are undergoing a simplified peer review process.
• Jurisdictions are also reporting statistics on their MAP functions and Advance Pricing Arrangements (APAs), improving transparency and data availability.

Additional Workstreams

• Tax, Inequality and Growth: A new workstream was introduced to explore the interaction between tax policy, inequality, and growth using a phased, evidence-based approach.
• Global Mobility: The Inclusive Framework is examining the tax implications of global mobility, including the impact of cross-border employment and the need for international cooperation.

OECD Support and Development

• The OECD continues to mainstream its development work, hosting annual stakeholder programmes and launching toolkits to support developing countries in managing tax challenges in the extractive sector.
• The OECD is also working on simplification measures and a report on potential scoping for an international framework to enhance real estate tax transparency.
• A report on simplifying international tax rules for developing countries and businesses is expected before the October meeting.

Conclusion

The OECD is making significant strides in advancing international tax reforms, enhancing transparency, and supporting developing countries. These efforts are crucial for ensuring a stable, equitable, and efficient international tax system that supports global economic growth and development. The report highlights the importance of continued collaboration, evidence-based policy-making, and the implementation of the Two-Pillar Solution to address Base Erosion and Profit Shifting risks effectively.