OECD Tax Allocation Framework Excludes Regulated Financial Services

As part of global efforts to acknowledge the large and growing role of digital activities in the economy, the Organization for Economic Cooperation and Development’s 139-member “Inclusive Framework” today endorsed an agreement on how large multinational firms allocate their profits in different tax jurisdictions. The framework envisions a global minimum tax on multinationals of 15%.

The allocation framework, known as Pillar One, explicitly excludes “regulated financial services,” according to the OECD statement. Pillar One applies to companies with gross receipts exceeding €20 billion and profit margins of more than 10%. Pillar Two, the global minimum tax—which would be implemented through interlocking domestic rules and a treaty-based rule—would apply to multinationals with consolidated group revenues of at least €750 million that are already subject to country-by-country reporting under the OECD’s existing Inclusive Framework.

These are high-level key components of the agreements and will require significant additional efforts to prepare operating rules for potential adoption in participating countries. ABA will continue to monitor and advocate on these issues through the International Banking Federation.