In late June 2025, the Group of Seven nations (Canada, France, Germany, Italy, Japan, the U.K., and the U.S.) reached a pivotal agreement: U.S.-headquartered multinationals will be exempt from paying the internationally agreed-upon 15% global minimum tax under the OECD’s Pillar Two framework. This “side-by-side” tax system allows U.S. companies to continue operating under their domestic tax rules, foregoing certain top-up levies applied in other countries
The arrangement emerged after the U.S. scrapped Section 899—its retaliatory “revenge tax” proposal that threatened to penalize foreign companies operating in the U.S. The G7’s compromise recognizes U.S. tax sovereignty while promising stability in global tax architecture
Supporters argue the deal ensures clarity and avoids double taxation. However, critics claim the exemption privileges U.S. corporations and undermines the spirit of multilateral tax justice, particularly disadvantaging non-U.S. firms and developing nations
This G7-level agreement must now be adopted by the full OECD/G20 Inclusive Framework, which includes over 140 countries. Many are concerned that carving out the U.S. could destabilize the global tax regime
The G7’s decision underscores a rising trend where powerful economies, especially the U.S., assert control over domestic tax structures. This challenges the ability of international frameworks, like OECD Pillar Two, to enforce uniform standards globally.
By exempting U.S. multinationals, the deal may tilt competitive balance toward U.S. firms—potentially enabling profit shifting and eroding tax bases in smaller economies that rely heavily on fair taxation.
This move establishes a “side-by-side” template that could be replicated, benefiting large economies in trade, climate, or digital regulation deals—an arena where developing nations may hold less sway.
Students preparing for exams like IAS or SSC must understand multilateral tax frameworks (e.g., OECD’s Inclusive Framework), international diplomacy, and the significance of how G7 decisions influence domestic and global policy contexts.
First proposed in 2019 and finalized in 2021, this two-pillar plan aimed to curb tax base erosion and digital-era profit shifting. Pillar Two enforces a minimum 15% corporate tax on firms with revenues above €750 million
Under President Biden, the U.S. supported the 2021 agreement. However, Trump, returning to power in 2025, reversed course—issuing an executive order to withdraw and legislating Section 899 to penalize foreign digital levies
Countries like France, Germany, Japan, and the U.K. initially pushed Pillar Two implementation in 2024. They have since shifted strategies to avoid outright conflict with the U.S., culminating in this latest G7 compromise .
The Global Minimum Tax is a 15% minimum corporate tax rate agreed upon by 140+ countries under the OECD/G20 Inclusive Framework. It targets large multinational corporations to prevent profit shifting and base erosion.
The G7 nations agreed to a “side-by-side” system that exempts U.S.-headquartered firms from the top-up taxes outlined in the global minimum tax plan. This means U.S. companies will not face double taxation in countries implementing Pillar Two.
Section 899 was a proposed U.S. tax rule aimed at retaliating against foreign countries that imposed digital services taxes on American companies. Its withdrawal was part of the compromise with G7 nations.
The G7 includes the United States, Canada, United Kingdom, France, Germany, Italy, and Japan. These nations are among the world’s largest advanced economies.
It covers topics related to international organizations (OECD, G7), taxation, global economic diplomacy, and fiscal policy—all crucial for UPSC, SSC, and other government exams.
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