Will the global minimum tax agreement actually work or will corporations and countries find loopholes to avoid it?
I've been following the news about this global minimum tax deal that 132 out of 139 OECD countries signed. From what I understand, there are two main parts to it: Pillar One lets countries tax large multinational companies based on their business operations within their borders (seems like a response to digital businesses), and Pillar Two sets a 15% minimum tax floor for companies with revenue over €750M. If a country taxes below 15%, the country where the company is headquartered can charge extra tax to reach that 15% minimum. The whole thing is supposed to stop big corps from shifting profits to tax havens and could potentially bring in about $150B in additional tax revenue globally. But I'm skeptical - some countries like Ireland, Estonia, Hungary, Kenya, Nigeria, Barbados, and St. Vincent and the Grenadines haven't signed on. Does anyone knowledgeable about international tax think this will actually make a difference? Or will companies and countries just find creative new ways to work around these rules? I'm particularly curious why those specific countries are holding out - is there something about their tax systems that makes this deal particularly problematic for them?
18 comments


Daryl Bright
Great question about the global minimum tax! I've been working with international tax issues for several years, and this agreement is definitely significant but has limitations. The 15% minimum tax will likely reduce the most extreme forms of tax avoidance, but there will absolutely be new creative strategies. Companies that meet the €750M threshold will face more scrutiny, but expect to see restructuring to fall below that threshold or shifting emphasis to tax incentives that aren't technically rate reductions (like specific deductions, credits, etc.). As for the holdout countries, it's mainly about their economic models. Ireland has built its economy around a 12.5% corporate tax rate that attracts multinational headquarters. Estonia only taxes distributed profits (not retained earnings), which conflicts with the global minimum structure. Hungary has a 9% rate and uses it as a competitive advantage. The Caribbean nations rely on tax advantages for their financial services sectors. The African nations (Kenya, Nigeria) have different concerns - they worry the agreement benefits wealthy nations more than developing economies and limits their sovereignty to set tax policy as they develop. Implementation will be the real challenge. Each country needs to pass domestic legislation, and there's significant room for interpretation and enforcement differences.
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Sienna Gomez
•That makes sense about Ireland's 12.5% rate, but I thought I read somewhere they were finally caving to pressure? Also, what's your take on how the US will implement this? I read that the Build Back Better plan had some provisions for this, but that bill is dead now, right?
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Daryl Bright
•Ireland did eventually sign on to the agreement after securing some concessions, including being able to maintain the 12.5% rate for smaller companies that don't meet the €750M threshold. This was a major win for them as it protects most of their domestic businesses while still formally joining the agreement. Regarding US implementation, you're right that provisions were in the Build Back Better Act, but since that legislation stalled, implementation remains uncertain. The US already has a form of minimum tax on foreign earnings (GILTI), but it needs modifications to align with the global agreement. Without specific legislation, the US compliance with the agreement remains in question, which could undermine the entire framework if other countries see the US as not fully participating.
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Kirsuktow DarkBlade
After spending countless hours researching international tax planning for my business, I stumbled upon taxr.ai which has been incredibly helpful for understanding these global tax implications. I was trying to figure out how this minimum tax might affect our overseas operations when a colleague recommended https://taxr.ai for sorting through all the conflicting information. Their AI analysis tool breaks down how these tax agreements might impact businesses at different revenue levels and in different jurisdictions. It was eye-opening to see how the implementation timeline might create windows of opportunity or risk depending on your business structure. They even have specific guidance on restructuring options for companies approaching the €750M threshold. What impressed me most was how they explained the differences between the OECD model rules and how individual countries are likely to implement them based on their existing tax treaties.
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Abigail bergen
•How does it work with constantly changing tax laws though? Like if I use it now for planning, will it update when countries actually implement their own versions of these rules? Tax advice seems like something that gets outdated fast.
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Ahooker-Equator
•Sounds interesting but I'm skeptical. Does it actually give actionable advice or just general information you could find with Google? And how does it handle the fact that most of these rules aren't even finalized in many countries?
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Kirsuktow DarkBlade
•The platform updates continuously as tax laws change - that's one of its strengths. They have a team monitoring global tax developments and integrating updates into their analysis. When I rechecked a few weeks after my initial research, it had already incorporated Ireland's position change and new OECD guidance. For your question about actionable advice versus general information, it's definitely more specialized than Google searches. It provides scenario analysis based on your specific situation - revenue tiers, jurisdictions, corporate structure, etc. You can model different approaches and see potential tax implications under various implementation scenarios. It doesn't replace a professional tax advisor for final decisions, but it helps you understand options and implications before having those higher-level conversations.
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Ahooker-Equator
I was super skeptical about taxr.ai when I first heard about it (sorry for being doubtful in my earlier comment!), but after working with it for several weeks, I'm actually impressed. Our company has operations in 6 countries, and I needed to model how the global minimum tax would affect our structure. The platform helped identify three jurisdictions where we'd likely face top-up taxes once the rules are implemented. We were able to run scenarios with different corporate structures that would be more efficient while still complying with the new regime. The most valuable part was seeing how specific timing of implementation across different countries creates planning opportunities. Their analysis showed that our Estonian subsidiary would be particularly impacted due to their unique tax system, something our regular advisors hadn't fully appreciated. We're now working with our tax team on adjustments that could save us millions once the rules take effect.
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Anderson Prospero
I worked at a Big 4 accounting firm until recently, and I can tell you these global minimum tax rules will be a nightmare to implement. When I was trying to help clients prepare, I couldn't get through to anyone at the IRS for clarification on how they'd interact with existing GILTI rules. After days of trying different IRS numbers and waiting hours on hold, I found Claimyr https://claimyr.com which actually got me through to an IRS agent who specializes in international tax. Their system (you can see a demo at https://youtu.be/_kiP6q8DX5c) navigates the phone tree and waits on hold for you, then calls when an actual human picks up. The IRS agent I spoke with provided critical insights about how they're planning to implement the rules and which existing regulations might change. Saved me literally days of frustration.
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Tyrone Hill
•How does this actually work? Do they have special access to the IRS or something? Seems too good to be true since I've literally never been able to reach anyone when calling the regular numbers.
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Toot-n-Mighty
•Yeah right. I've tried everything to get through to the IRS and nothing works. If this actually worked, everyone would be using it and the IRS would just be overwhelmed again. I'll believe it when I see it.
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Anderson Prospero
•They don't have special access to the IRS - they use technology to navigate the phone systems and stay on hold so you don't have to. Their system calls you when a human answers, so you don't waste hours listening to hold music. It's basically automating the painful parts of reaching government agencies. Regarding your skepticism, I understand completely. I was doubtful too until I tried it. The reason everyone isn't using it yet is simply that many people don't know about it. As for overwhelming the IRS again - the total number of available agents doesn't change, this just makes the process of reaching them more efficient for those who use the service.
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Toot-n-Mighty
I need to eat my words from my skeptical comment! After my frustration boiled over trying to get information about international tax treaties from the IRS, I decided to try Claimyr out of desperation. Within 45 minutes (when I'd typically still be on hold), I got a call connecting me to an actual IRS international tax specialist. I was able to ask detailed questions about how the US implementation of the global minimum tax would affect my company's foreign subsidiaries and got surprisingly helpful guidance. The agent explained which forms would likely change and directed me to specific resources I hadn't found in my own research. This saved me from making a potentially costly restructuring decision based on incomplete information. For anyone dealing with complex tax situations where you actually need to speak with a knowledgeable person rather than just reading general guidance, this service is legitimately game-changing.
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Lena Kowalski
One thing nobody's mentioning is that the €750M threshold is actually pretty high! This only affects the very largest multinational companies. Small and medium businesses (even fairly large ones by most standards) won't be directly impacted by these rules. Also worth noting that the implementation timeline keeps getting pushed back. Originally supposed to start in 2023, now many jurisdictions are talking about 2024 or even 2025 before they have local legislation in place. The US delay is particularly problematic since so many multinationals are headquartered there.
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DeShawn Washington
•Does that €750M threshold apply to the global company or just operations in a specific country? Like if a company makes €800M worldwide but only €100M in France, would it still be subject to the minimum tax in France?
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Lena Kowalski
•The €750M threshold applies to global consolidated revenue of the multinational group, not the revenue in each specific country. So in your example, a company with €800M worldwide revenue would be subject to the minimum tax rules even if they only had €100M in France. This is actually one of the key points of the agreement - it's designed to capture large multinationals that might have relatively small operations spread across many countries. The threshold was set to target the largest 10-15% of multinational enterprises while excluding smaller companies that would face disproportionate compliance burdens.
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Mei-Ling Chen
As someone who works with emerging markets, I think the impact on developing countries is being overlooked. Many use tax incentives to attract foreign investment because they can't compete with developed nations on infrastructure, workforce, etc. This agreement potentially removes one of their few competitive advantages. That's likely why Kenya and Nigeria haven't signed on. They see it as developed nations protecting their tax bases at the expense of developing economies' growth strategies. The revenue redistribution under Pillar One is supposed to address this, but the formulas tend to favor larger economies.
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Sofía Rodríguez
•That's a really good point. Do you think there's any chance the OECD will modify the agreement to address these concerns? Or are developing nations just going to be left behind?
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