On 8 October 2021 the Inclusive Framework (IF) on Base Erosion and Profit Shifting released details of an agreement which refines the statement of 1 July 2021. In terms of consensus, 136 of the 140 Inclusive Framework countries (including Malta) have agreed to this release, including Estonia, Hungary and Ireland which initially expressed concerns. The four countries that have not signed up are Kenya, Nigeria, Pakistan and Sri Lanka. 

It is titled Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy and is 8 pages in length.

Consistent with the statement of 1 July, covered previously, two Pillars are covered. Pillar 1 deals with the reallocation of certain profits from very large Multinational Enterprises (MNEs) to market jurisdictions. Pillar 2 deals with a Global Minimum Tax.

The statement annex includes a detailed implementation plan with timelines for the development of detailed rules, for legislative implementation, and target effective dates.

Read a more detailed write-up on the statement of October 2021 together with KPMG observations prepared by KPMG’s EU Tax Centre.


Attitudes to tax are changing. Organisations of all sizes are ever more exposed...