Inclusive Framework Agreement on the Global Minimum Tax: Recommendations to address stabilized fiscal conditions

A global minimum corporate tax will require many states to review their policies that may include tax incentives that are locked in by fiscal stabilization clauses.

Organisation for Economic Co-operation and Development/G20 Inclusive Framework members that agree to adopt the global minimum corporate tax will be required to implement and administer the rules in a way that is consistent with model legislation and a commentary approved by the Inclusive Framework.

This note provides recommendations on how the OECD could design the model legislation and commentary to effectively address the issue of stabilized tax incentives. It builds on IISD’s recent guidance to developing country governments on how to amend their tax incentives regimes to benefit from the minimum tax, as well as contributions from the Intergovernmental Forum on Mining, Minerals, Metals, and Sustainable Development on specific implementation issues of the global minimum tax in the mining sector.

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