OECD Inclusive Framework requests year-end plan for digital-tax discussions

The statement follows the Inclusive Framework’s 28–30 October meeting in Paris. For multinational groups, it signals further policy development rather than an immediate change to taxing rights. Members agreed to advance a common understanding of perceived difficulties in applying existing international tax rules to digital business models, before evaluating coordinated solutions.^[1][2]

Paragraph 8 asks the OECD Secretariat to develop a plan by the end of the year. The work is to examine evidence of the challenges and their relationship to current rules, drawing lessons from earlier work. Its stated objectives include preventing double taxation and fragmentation, protecting tax bases, respecting sovereignty and preserving certainty and stability. The statement does not itself adopt a digital-services tax or a new allocation formula.^[1]

Members also approved a plan for the next phase of work on the global mobility of workers, following the January consultation. The focus is greater tax certainty, simpler compliance and more effective administration for cross-border work. Employers should monitor the resulting work, but the announcement does not introduce a new payroll return, registration requirement or filing deadline.^[1][2]

On the Global Minimum Tax, members discussed an updated impact assessment, tax incentives, further simplification and implementation guidance. They welcomed progress on legislative reviews, the GloBE coordination mechanism and reviews of two pre-existing regimes seeking Side-by-Side safe-harbour qualification. This records ongoing work, not the outcome of those qualification reviews. Groups should continue applying the rules and qualifications actually in force in each jurisdiction rather than treating the plenary discussion as operative relief.^[1]