Overview
- More than 145 countries agreed to update the 2021 pact, preserving the 15% framework but reshaping how it applies to large American groups.
- The revision effectively shields U.S.-parented companies from key top‑up mechanisms such as the income inclusion and undertaxed profits rules through a side‑by‑side approach.
- OECD officials said the package reduces complexity and protects tax bases, while the U.S. Treasury hailed it as a victory for domestic control over American firms’ worldwide income.
- Tax watchdogs, including the FACT Coalition and economists like Gabriel Zucman, criticized the changes as a retreat that could weaken enforcement against profit shifting.
- The OECD’s prior extra‑revenue estimate stands at $192 billion before factoring in U.S. carve‑outs, and implementation work continues with new safe harbors and compliance simplifications.