History and Evolution of the Global Minimum Tax

1990s-2010s Foundations

Post-Ruding failure, G20 leaders in 2009 called for anti-BEPS measures; 2013 OECD BEPS Action 13 introduced Country-by-Country Reporting (CbCR), exposing profit mismatches but lacking enforcement.

Breakthrough

France and Germany revived minimum tax talks amid U.S. TCJA’s GILTI (10.5% undertaxed foreign income rate); OECD/G20 proposed Pillar Two in 2019, targeting €750M+ MNEs

2021 Endorsement

G7 finance ministers agreed to 15% in June 2021; 137 countries signed the Inclusive Framework statement by October, with GloBE Model Rules released December 2021.

2023-2024 Momentum

GloBE Rules finalized March 2023; EU Directive adopted December 2022, effective 2024 for fiscal years starting January; early adopters like Switzerland (January 2024) and UK/Japan (April 2023) legislate domestic rules.

2025 Pivots

OECD’s 2025 Consolidated Commentary integrates the latest administrative guidance. In June 2025, the G7 proposed a “side-by-side” system exempting U.S. parented groups from UTPR and IIR on both domestic and foreign profits.

【%】 The Future of Global Minimum Tax

  • The introduction of the Global Minimum Tax (GMT) is expected to trigger a broad restructuring among multinational corporations. As companies search for the most tax-efficient jurisdictions to report profits, governments with traditionally low corporate tax rates may adjust upward to minimize the need for GMT “top-up” payments. At the same time, countries are likely to design new incentive packages to maintain competitiveness and attract foreign investment.
  • Before the OECD’s GMT initiative, many jurisdictions experimented with Digital Services Taxes (DST), which are applied on revenues rather than profits. As GMT becomes effective, adjustments to DST regimes may also follow to avoid overlap and ensure alignment with global standards. While GMT primarily targets large multinational groups, smaller businesses and subsidiaries may feel a ripple effect through supply chains, compliance obligations, and investment policies.
  • Because GMT reshapes multiple dimensions of tax practice — from rules and reporting frameworks to compliance requirements — tax professionals face significant challenges. With implementation expected in 2024 and beyond, companies must develop proactive strategies to meet documentation requirements, minimize risks, and optimize their global tax position. Alarmingly, 57% of tax departments report insufficient resources to manage GMT obligations, underscoring the need for expert advisory support.
  • GMT represents the first truly coordinated international effort to address profit shifting and global tax equity under the OECD’s Base Erosion and Profit Shifting (BEPS) framework. For advisors and tax professionals, this transition is not only a compliance challenge but also an opportunity to invest in stronger systems, advanced tools, and cross-border expertise — ultimately helping businesses adapt and thrive in a new era of international taxation.

Ready to navigate Global Minimum Tax and turn compliance into strategic advantage?

 

We provide Global Minimum Tax advisory with clarity and compliance, empowering you to focus on sustainable growth

Schedule a 30-minutes call

 

with our consultant and get solutions for your
business in Vietnam.

Hotline: +8498 498 0069 Email: infor@vinatpt.com

CONTACT US

 







    © 2025 UX Themes
    Terms Privacy Cookies

    VINA TPT COMPANY LIMITED
    Tax Identification Number: 0315968958

    THE CLASSLIB COMPANY LIMITED
    Tax Identification Number: 0313916707

    Tel: +8428 730 40 790 | Email: infor@vinatpt.com
    Office: 5th Floor, More Building, 83B Hoang Sa Street, Tan Dinh Ward, Ho Chi Minh City, Vietnam

     
    © 2025 Vina TPT