Overview
- The G7 communiqué officially carves U.S. multinationals out of the 15% global minimum tax established under the OECD pillar-two agreement.
- In place of the uniform floor, American companies will be subject to a “sistema yuxtapuesto” that aligns with existing U.S. corporate tax laws.
- President Trump issued an executive order in January declaring the OECD deal non-applicable in the United States and secured repeal of the Section 889 retaliation clause before the G7 accord.
- Treasury Secretary Scott Bessent said the exemption defends U.S. interests and will avert more than $100 billion in potential taxpayer liabilities.
- The OECD now faces a decision on whether to formalize the carve-out, a move that could reshape multilateral tax cooperation.