OECD_经合组织秘书长向G20领导人提交的税务报告（G20南非_2025年11月）_22页_885kb

OECD Secretary-General Tax Report to G20 Leaders (South Africa, November 2025)

Core Content Summary

This report outlines key developments in international tax policy since the last OECD report to G20 Leaders in November 2024. It focuses on progress made in the implementation of the OECD/G20 Inclusive Framework on BEPS, the global minimum tax, tax transparency, and new work items related to tax, inequality, and growth, as well as global mobility.

Main Points and Key Information

1. Support for G20 Initiatives

• The OECD has supported G20 priorities for over 15 years, including enhancing tax transparency, tackling tax avoidance, and promoting stability.
• The South African G20 Presidency requested updates on BEPS and tax transparency, leading to the preparation of two reports:
  • A Decade of the BEPS Initiative: Assesses the economic impact and progress of the BEPS Project.
  • Taking Stock of Progress on Transparency and Exchange of Information for Tax Purposes: Highlights the transformation in tax transparency over the past 15 years.
• Additional reports addressed simplification, real estate information exchange, and the interaction of tax policy with inequality and growth.

2. Progress on the Implementation of the Global Minimum Tax

• The global minimum tax, part of the Two-Pillar Solution, has been implemented in over 65 jurisdictions.
• A central record of implemented legislation was updated in August 2025, listing 42 Qualified Income Inclusion regimes and 43 Qualified Domestic Minimum Top-up Tax regimes.
• The US expressed concerns about the interaction between the global minimum tax and its own regime, leading to discussions on a "side-by-side" approach.
• The G7 and G20 have endorsed a potential side-by-side system to preserve the gains of Pillar Two while ensuring stability and a level playing field.
• A Multilateral Competent Authority Agreement (GIR MCAA) is being developed to facilitate the automatic exchange of GloBE Information Returns.

3. Continuing the BEPS Journey

• The BEPS Project has made significant progress, particularly in the implementation of the four minimum standards (Actions 5, 6, 13, and 14).
• Action 5 (Harmful Tax Practices):
  • Over 300 preferential regimes have been examined.
  • Almost all regimes with BEPS risks have been amended or abolished.
• Action 6 (Tax Treaty Abuse):
  • Over 95% of tax treaties among Inclusive Framework members are compliant or on track to be compliant.
• Action 13 (CbC Reporting):
  • 120 jurisdictions have implemented CbC legislation.
  • Over 4,600 bilateral relationships facilitate CbC report exchanges.
• Action 14 (Mutual Agreement Procedures):
  • Over 500 treaties have been modified to include effective MAP provisions.
  • MAP agreements are increasingly implemented, with many jurisdictions resolving disputes within 24 months.

4. New Inclusive Framework Work Items

• Tax, Inequality and Growth:
  • Agreed as a new workstream in April 2025.
  • Focuses on understanding the interactions between tax policy, inequality, and growth.
  • Aims to build an evidence-based understanding and inform domestic and international policy responses.
  • Will be phased, analytical, and build on existing work in tax transparency and BEPS.
• Global Mobility:
  • The Inclusive Framework will explore tax issues related to the global mobility of individuals.
  • Addresses the challenges posed by cross-border and remote working.
  • Aims to update tax administration and compliance obligations to ensure certainty and reduce burdens.

5. Developments in Tax Transparency

• The Global Forum on Transparency and Exchange of Information for Tax Purposes has been central to promoting tax transparency and addressing offshore tax evasion.
• Tax Transparency in Africa:
  • The 2025 report highlights major progress in 39 African jurisdictions.
  • 1,756 EOI requests were sent in 2024, doubling the number from 2023.
  • 6 jurisdictions are already conducting automatic exchanges, with 12 committed by 2026.
  • 5 jurisdictions plan to implement the CARF by 2027 or 2028.
• Capacity Building:
  • Over 7,900 officials from 177 jurisdictions have been trained on tax transparency.
  • 1,500 officials received training on the CARF, with a Masterclass attended by 470 officials from 61 jurisdictions.

6. OECD Tax and Development Work

• The OECD continues to support developing countries in implementing tax reforms.
• Focus areas include simplification of international tax rules, access to CbC reports, and capacity-building through technical assistance.
• Collaboration with development partners and the Platform for Collaboration on Tax is encouraged to support these efforts.

Key Outcomes and Metrics

• Profits-to-employees ratio: Down by 27% in investment hubs.
• Profit location sensitivity: Declined by 12% to 40% relative to pre-2015 estimates.
• Statutory CIT rates: Stabilised over the last five years.
• CbC reporting: 98% of global outbound FDI jurisdictions have introduced CbCR.
• Tax ruling information exchange: 92% of global GDP jurisdictions are exchanging information on rulings.

Future Priorities

• The Inclusive Framework will continue to monitor the impact of the BEPS Project and publish aggregated CbCR data.
• Efforts to simplify and streamline processes will be prioritised to improve efficiency.
• The work on tax, inequality, and growth will proceed through a structured, evidence-based approach.
• The Global Mobility workstream will advance with technical discussions and a planned work plan for 2026.
• The OECD will support the implementation of further measures to address the challenges of the digital economy, including VAT guidelines for e-commerce.