Executive summary

On 15-16 October 2025, the G20 Finance Ministers and Central Bank Governors met in Washington, DC, in connection with the annual meetings of the World Bank Group and International Monetary Fund (IMF). The Chair's Summary released at the conclusion of the meeting includes a section on international taxation.

The Chair's Summary notes members' commitment to continue engaging constructively to address concerns regarding Pillar Two global minimum taxes, with the shared goal of finding a balanced and practical solution acceptable to all as soon as possible. It indicates that delivery will include commitments to address level playing field risks, including the fair treatment of substance-based tax incentives and risks of base erosion and profit shifting (BEPS), and to advance constructive dialogue on the tax challenges arising from digitalization. It further notes that these efforts will be advanced in the Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework, preserving the tax sovereignty of all countries. Beyond Pillar Two, the Summary briefly references other ongoing international tax work in the Inclusive Framework, the United Nations (UN) and other organizations.

In advance of the meeting, the OECD released its customary Secretary-General Tax Report to the G20 Finance Ministers. The Report provides an update on key international tax developments since July 2025, outlining ongoing work in the Inclusive Framework to address concerns related to Pillar Two which includes discussion of a proposed "side-by-side" arrangement. It also includes updates on workstreams related to simplification, tax transparency, capacity building and tax administration. At the request of the South African G20 Presidency, two new documents were produced and are included as annexes to the Secretary-General Tax Report: Annex A, A Decade of the BEPS Initiative, which takes stock of BEPS implementation since 2015 and assesses its economic impacts, and Annex B, a Framework for the Automatic Exchange of Readily Available Information on Immovable Property for Tax Purposes. In addition, the OECD is preparing a report, Enhancing Simplicity to Foster Tax Certainty and Growth, which will be released subsequently.

Detailed discussion

G20 Chair's Summary

The international tax section of the Chair's Summary from the G20 Finance Ministers meeting first addresses ongoing work on Pillar Two, echoing the language included in the agreed communiqué issued following the group's July 2025 meeting:

Members committed to continue engaging constructively to address concerns regarding Pillar Two global minimum taxes, with the shared goal of finding a balanced and practical solution that is acceptable to all as soon as possible. Delivery of a solution will need to include a commitment to ensure any substantial risks that may be identified with respect to the level playing field, including a discussion of the fair treatment of substance-based tax incentives, and risks of base erosion and profit shifting, are addressed and will facilitate further progress to stabilise the international tax system, including a constructive dialogue on the tax challenges arising from the digitalisation of the economy. These efforts will be advanced in close cooperation across the membership of the OECD/G20 Inclusive Framework (IF), preserving the tax sovereignty of all countries.

Beyond Pillar Two, the Summary states that members welcomed the Inclusive Framework's phased, evidence-based approach to exploring global mobility and understanding the interaction between tax policy, inequality and growth. It notes ongoing negotiations toward a UN Framework Convention on International Tax Cooperation, indicating that participating G20 members reaffirmed the objectives to reach broad consensus and build on existing achievements and work by international organizations, while seeking to avoid unnecessary duplication.

The Summary also states that members welcomed reports presented in connection with the meeting, including the Inclusive Framework document "A Decade of the BEPS Initiative" and the OECD framework for the automatic exchange of readily available information on immovable property. It further highlights work on domestic resource mobilization, referencing the IMF background note on strengthening revenue administration and the Platform for Collaboration on Tax (PCT) report on capacity-building frameworks. Finally, the Summary indicates that members look forward to the PCT Tax and Development Conference in Tokyo next year and to receiving the report "Enhancing Simplicity to Foster Tax Certainty and Growth," which the OECD is preparing.

OECD Secretary-General Tax Report

The OECD Secretary-General Tax Report provides an overview of recent developments in international tax cooperation since July 2025 and reiterates the OECD's support for the G20's tax agenda, covering ongoing activity on Pillar Two, the implementation of the BEPS minimum standards and other tax projects.

Support for G20 initiatives

The Report includes an update on the OECD's progress on requests from the G20. At the request of the South African G20 Presidency, two stock-taking reports were produced this year: an assessment of the progress and economic impact of the BEPS Project, provided as Annex A to the current Report, and a report on tax transparency included in the July 2025 Secretary-General Tax Report (see EY Global Tax Alert, G20 Finance Ministers meeting communiqué includes international tax section, dated 28 July 2025). Also in response to a request from the South African Presidency, the current Report includes, as Annex B, a framework to enable the automatic exchange of readily available information on immovable property for tax purposes. In this regard, the OECD is working with interested countries to assess the feasibility of enhancing transparency through cross-border access to information in ownership registers.

The Report also notes ongoing work to identify ways to simplify international tax rules while improving tax certainty to reduce compliance costs for both taxpayers and tax administrations and foster growth and cross border investment. A separate report on simplification and tax certainty will be forthcoming.

Finally, the report reiterates that the Inclusive Framework has agreed to consider the interaction of tax policy, inequality and growth, beginning with a scoping and diagnostic phase that relies on data and economic analysis and facilitates the sharing of experiences with domestic policy tools.

Pillars One and Two

On Pillar Two, the Report indicates that the implementation of the Global Anti-Base Erosion (GLoBE) rules continues to expand. More than 65 jurisdictions have implemented, or taken concrete steps to implement, the GloBE Rules or a Qualified Domestic Minimum Top-up Tax. The central record of qualified legislation, first released in January 2025 and updated in March 2025 and August 2025, lists 42 Qualified Income Inclusion Rule regimes and 43 Qualified Domestic Minimum Top-up Tax regimes under the transitional qualification mechanism, with full legislative review and ongoing monitoring being developed.

The Report notes that concerns raised by the United States regarding duplicative tax systems and multiple taxation for US multinational enterprises (MNEs) were discussed at the April 2025 Inclusive Framework plenary. In June 2025, the G7 issued a statement announcing an understanding outlining parameters for a potential "side-by-side" arrangement intended to preserve the gains of Pillar Two while supporting stability and certainty (see EY Global Tax Alert, G7 issues statement on global minimum taxes, dated 9 July 2025). This was followed by language in the July 2025 G20 communiqué referencing continued engagement to constructively address concerns regarding Pillar Two. The Report indicates that Inclusive Framework members are undertaking technical work on design and impact, with progress continuing and hope for a solution acceptable to all members by the end of the year.

The Report states that Pillar Two simplification efforts continue in response to stakeholder feedback. The Inclusive Framework is developing a simplified effective tax rate calculation for a safe harbor for MNE groups operating in high effective-tax-rate jurisdictions. The Report notes that a draft structure was shared with business representatives mid-year and a revised version will be considered by Working Party 11 (the OECD working group that focuses on aggressive tax planning and BEPS), with a view to finalization before the end of 2025.

According to the Report, work on improving administrative coordination is progressing through the "Amsterdam Dialogue," a joint OECD-Forum on Tax Administration initiative to share experience and promote consistent administration of the global minimum tax, including potential common approaches and tools.

Finally, the Report indicates that a compilation of GloBE-related information requirements beyond the GloBE Information Return and notifications was released in August 2025 and will be updated regularly to support compliance. The Multilateral Competent Authority Agreement on the Exchange of GloBE Information, released in January 2025, is open for signature and currently has 20 signatories. To operationalize exchanges, the GloBE Information Return XML Schema and user guide were issued in January 2025 (see EY Global Tax Alert, OECD releases new documents on GloBE Information Return, dated 21 January 2025), and a Status Message XML Schema was published in July 2025 to help competent authorities confirm whether exchanged information meets agreed validation rules (see EY Global Tax Alert, The Latest on BEPS and Beyond | September 2025, dated 19 September 2025).

BEPS minimum standards

Regarding Action 5 on harmful tax practices, the Report indicates that monitoring continues across more than 130 jurisdictions. As of December 2024, more than 58,000 exchanges of tax rulings had occurred. The Inclusive Framework released revisions to the transparency framework on tax rulings in September 2025 to enhance the quality and efficiency of exchanges (see EY Global Tax Alert, OECD publishes 'Revised BEPS Action 5 Transparency Framework on Tax Rulings', dated 16 September 2025). The Forum on Harmful Tax Practices has reviewed 332 regimes, finding almost all to be aligned to the standard and more than 40% abolished or in the process of being abolished. A revised peer-review methodology approved in April 2025 introduces an initial BEPS-impact assessment before legislative review to reduce burdens, particularly for developing countries. The 11 no-tax or nominal-tax jurisdictions have been reviewed for the fifth consecutive year and all have introduced economic substance requirements. The next monitoring exercise will take place in the second half of 2025.

Regarding Action 6 on tax treaty abuse, the Report states that implementation of the minimum standard has advanced primarily through the BEPS Multilateral Instrument (MLI), which covers 105 jurisdictions (with 89 having ratified) and approximately 2,000 bilateral tax treaties. The MLI has effectively modified more than 1,500 treaties, with a further 500 to be modified once all signatories ratify. More than 90% of treaties between Inclusive Framework members are compliant with the minimum standard, subject to a complying instrument, or subject to steps taken by at least one treaty partner to implement the minimum standard.

Regarding Action 13 on transfer pricing documentation, the Report indicates that more than 120 Inclusive Framework members have introduced legislation to require filing a Country-by-Country (CbC) report, covering substantially all groups exceeding the €750m threshold. There are more than 4,600 bilateral exchange relationships in place, and 82 Inclusive Framework members have completed the building blocks necessary to receive reports on exchange. The eighth annual peer review report, covering 142 Inclusive Framework members as of 31 March 2025 and released in September 2025, shows largely consistent implementation where legislation exists, with 16 jurisdictions having taken steps to address prior recommendations for improvements (see EY Global Tax Alert, OECD releases outcomes of eighth peer review on BEPS Action 13 on country-by-country reporting, dated 23 September 2025). Capacity-building efforts have provided support, and 30 developing countries now have CbC reporting fully in place, including 13 that completed the steps to receive reports since July 2023.

Regarding Action 14 on Mutual Agreement Procedure, the Report indicates that peer reviews are continuing. To date, 82 jurisdictions have completed two stages of review. A full peer review cycle is underway for 55 jurisdictions with meaningful MAP experience. Reviews have started for 30 of these jurisdictions, with 18 completed and final reports already published or expected soon. In addition, 77 jurisdictions with limited or no MAP experience have undergone or are undergoing a simplified review process, with 60 reports already published. Nine more jurisdictions are scheduled for review. In addition, the Report notes that jurisdictions are reporting MAP statistics and, starting in 2024, statistics on Advance Pricing Arrangements.

Other tax work

The Report indicates that the OECD is continuing to update the Transfer Pricing Country Profiles that it began publishing in 2006 and that that now cover 78 jurisdictions, including all OECD member countries. The 2025 updates expand coverage among Inclusive Framework members, including a new section on Amount B. On the work on tax, inequality and growth, which is a G20 focus, the Report indicates that the OECD Secretariat is working toward developing a work plan in 2025 for the scoping and diagnostic phase.

The Report states that the Inclusive Framework has begun work on global mobility of individuals to reflect changing work patterns, including cross-border and remote working. Inputs are being gathered from members and stakeholders, with technical discussions planned. The OECD Secretariat anticipates reporting to the Inclusive Framework plenary in early 2026, with a view to reaching agreement on a work plan going forward.

Regarding the work on tax policy and statistics, the Report notes the 2025 Tax Policy Reforms report published in September 2025, which reviews reforms implemented in 2024 across 86 jurisdictions. With respect to the Inclusive Forum on Carbon Mitigation Approaches, the Report notes that work has progressed on interoperable carbon intensity metrics, with two papers published in June 2025 and a methodological framework to analyze international spillovers from climate action presented at the Forum's plenary in June 2025.

The Report indicates that capacity-building support continues to expand. In 2025, more than 40 developing countries have benefited from bilateral programs and more than 6,000 tax officials have participated in multilateral and regional training. Following the April 2025 Inclusive Framework plenary, implementation has begun on a new strategy for tailored assistance to help low- and middle-income countries access and use CbC reports, including low- or no-cost IT tools. The annual OECD/UN Development Programme Tax Inspectors Without Borders Stakeholders Workshop was held virtually on 16-17 October 2025 to discuss implementation of "TIWB 2.0," which aims to expand partnerships and peer-led support to countries facing international tax challenges. At the request of the G20 Presidency, the PCT prepared a report on progress in strengthening frameworks for building tax capacity, including an agenda for tax-related capacity development for the medium term.

The Report also provides an update on the tax transparency work of the Global Forum on Transparency and Exchange of Information for Tax Purposes since the last report in July 2025. Membership reached 173 jurisdictions with Sri Lanka joining in September 2025. Vietnam endorsed the Bali Declaration in August 2025, becoming the 18th member of the Asia Initiative. Zimbabwe joined as the 151st signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in July 2025, and Madagascar deposited its instrument of ratification that same month. In addition, five new exchange-of-information-on-request peer-review reports were approved in July 2025, with Oman and Trinidad and Tobago rated "Largely Compliant" and Honduras, Madagascar and Mongolia assessed on legal and regulatory frameworks in Phase 1 due to limited practice. One additional jurisdiction has committed to implement the Crypto-Asset Reporting Framework (CARF) since July 2025, bringing the total to 70. Finally, the Report indicates that the Tax Transparency in Africa 2025 report shows increased exchange of information activity across 39 African jurisdictions, with at least €4.2b in additional revenue uncovered since 2009, growth in bilateral exchange relationships and additional commitments to automatic exchanges and CARF implementation.

A decade of the BEPS initiative

The document taking stock of the BEPS project, released as Annex A to the Secretary-General Tax Report, reviews the implementation of the BEPS package since 2015 and assesses its economic impact. The document covers the BEPS agenda across coherence, substance and transparency, noting broad implementation by Inclusive Framework members of the minimum standards and the wider set of BEPS recommendations, including in areas such as controlled foreign company rules, interest limitations, transfer pricing rules, VAT on digital trade and the multilateral instrument for implementing tax treaty measures.

According to the document, which notes limitations on data availability and issues with respect to data quality, there are indications that the BEPS project has contributed to closer alignment between the location of profits and underlying economic activity, a reduced sensitivity of profit location to tax-rate differentials, a stabilization of statutory corporate income tax rates after a prolonged period of decline and greater transparency through CbC reporting and exchanges of tax rulings. The document also notes an expansion in the use of the Mutual Agreement Procedure (MAP) to resolve disputes.

The document acknowledges ongoing challenges, particularly for developing countries, including capacity constraints and the complexity of implementation. It highlights the importance of continued simplification to support effective administration and tax certainty, ongoing monitoring of implementation and impact and targeted capacity-building to help all jurisdictions make full use of BEPS tools and realize domestic resource mobilization benefits.

Looking ahead, the document states that BEPS challenges and competitive pressures remain, exacerbated by trends such as increasing digitalization and increasing intangible intensity. It indicates that the OECD Secretariat can support the Inclusive Framework members in the next phase of work on: continued monitoring of implementation and economic effects of the BEPS project and Pillar Two; simplifying Inclusive Framework processes to reduce burdens and ensure its operating procedures are responsive to the needs of its members; supporting implementation of the BEPS Actions in developing countries, with an emphasis on access to CbC reports and interest limitation rules; supporting implementation of further measures to address challenges arising from the digital economy; and ensuring open dialogue with the business community, non-governmental organizations and other stakeholders. The document also notes that the Inclusive Framework will continue evidence-based analysis in other areas such as global mobility and the interaction of tax policy with inequality and growth, which have connections with the BEPS agenda and wider policy relevance.

Framework for the Automatic Exchange of Readily Available Information on Immovable Property

The document on automatic exchange of readily available information on immovable property, released as Annex B to the Secretary-General Tax Report, sets out a voluntary approach for the automatic exchange of tax-relevant information on immovable property. The framework is formalized through a Multilateral Competent Authority Agreement on the Exchange of Readily Available Information on Immovable Property (International Project Institute (IPI) MCAA), which is based on the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. It uses information already available to tax administrations or accessible from existing government registries and does not introduce new domestic reporting obligations. It also builds on the infrastructure developed for the Common Reporting Standard, including a standardized XML schema and the OECD's secure Common Transmission System, and applies the Convention's confidentiality and use-limitation rules.

The IPI MCAA defines "Readily Available Information" as information that is electronically captured, searchable and sortable and that is in databases maintained by the tax administration or maintained by other authorities directly accessible by the tax administration (such as real estate registers and beneficial owner registers). This does not include PDF or paper records or other information that can only accessed on an item-by-item basis, although tax administrations can choose to include such information in their exchanges if they consider the information to be readily accessible.

Information is to be exchanged under the IPI MCAA if it includes the Minimum Data Set for a specific category of information and is sufficiently current and reliable to be appropriate for exchange. The elements covered in the minimum data requirements are identifying information with respect to the relevant individuals or entities and identifying and quantitative information with respect to the immovable property assets and income. Competent Authorities are expected to do a self-assessment to determine the relevant information on immovable property they have that is readily available and appropriate for exchange. They will notify other Competent Authorities participating in the IPI MCAA regarding which information items they can exchange.

The IPI MCAA uses a modular structure so that jurisdictions can tailor their arrangements with each partner. Module 1 covers information on holdings and acquisitions of immovable property through a one-off exchange of information on existing holdings and annual exchanges of information on new acquisitions. Module 2 covers information on income from immovable property through annual exchanges on disposals and income. Information is exchanged reciprocally on an "as-is" basis to the extent it is readily available in the sending jurisdiction.

The IPI MCAA provides defined timelines for the one-off and annual exchanges. It also specifies the steps for activating participation, sets technical and procedural safeguards, and includes confidentiality obligations. The OECD will maintain a public list of signatories and active exchange relationships.

Implications

The international tax section of the G20 Chair's Summary reflects the evolving tax priorities of the G20. The Secretary-General Tax Report provides information on the OECD's current work on various tax initiatives, including Pillar Two, implementation of the BEPS minimum standards and tax transparency. It also provides a view into the OECD's plans for future tax work, including new work on the interaction of tax policy and inequality and growth and updating relevant international tax rules in light of increased global mobility and continued focus on addressing BEPS. With the new immovable property framework, countries that choose to do will have a mechanism to establish automatic exchange of information relationships covering information on real estate holdings, acquisitions and disposals and income.

Businesses should monitor tax discussions in the G20 and the ongoing tax work of the OECD and other international organizations. Staying informed about tax proposals as they evolve and develop is helpful in navigating the complexities of the global tax landscape.