This proposal considers the introduction of a global minimum effective corporate tax as part of a broader reform of international tax rules under the United Nations Framework Convention on International Tax Cooperation. The minimum tax would be implemented alongside existing and emerging measures on country-by-country reporting and beneficial ownership transparency, as well as reforms to the allocation of taxing rights based on real economic activity. This includes progress towards unitary taxation, moving beyond the separate-entity and transfer-pricing approach that currently governs international corporate taxation. By treating multinational groups as single firms, unitary taxation would support a fairer allocation of profits across jurisdictions and strengthen the effectiveness of measures to curb profit shifting. The proposal would increase and stabilise public revenues, reduce incentives for profit shifting, and rebalance taxing rights in favour of countries where economic activity takes place. In doing so, it would expand fiscal space, particularly in the Global South, while contributing to a more equitable distribution of the tax responsibilities and strengthening accountability in tax systems. The OECD global minimum corporate tax is a coordinated international agreement (adopted in 2021) to ensure large multinational companies pay at least a set minimum tax rate of 15% on their profits in every country where they operate. It applies to large multinational groups with annual global revenues of at least about EUR 750 million. The aim is to reduce the incentive to shift profits to tax havens and curb harmful competition between countries. At the same time, important limitations have been identified: certain multinational groups, including some headquartered in major economies, may be only partially captured in practice; the agreed minimum rate of 15% has been widely criticised as relatively low; and there are concerns that countries may offset additional revenues through subsidies or other measures, potentially limiting the intended redistributive impact. While a global minimum tax has the potential to recover significant revenues and contribute to financing public services and social protection systems, these outcomes will depend on the strength of implementation, the level of the minimum rate, and the extent to which such limitations are addressed.
