Statement by co-chairs of Inclusive Framework on BEPS indicates still no consensus on Pillar One

The statement indicates that the co-chairs intend to continue working to achieve a consensus on the Amount B Framework and so the overall Pillar One package.

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January 13, 2025

The Organisation for Economic Cooperation and Development (OECD) today released a statement by the co-chairs of the Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS) providing an update on Pillar One.

The co-chairs state the IF members have stabilized the text of a Multilateral Convention (MLC) on Amount A, but have been unable to reach agreement on the mandatory application of Amount B by jurisdictions that implement the Amount A MLC (the “Amount B Framework”) and hence have still been unable to reach a final agreement on the implementation of Pillar One.

The statement indicates that the co-chairs intend to continue working to achieve a consensus on the Amount B Framework and so the overall Pillar One package.

KPMG observation
Attention will understandably turn to the views of the incoming Trump Administration on Pillar One, however, it is notable that the current administration (which has been a strong proponent of the OECD’s work on international tax) has ultimately been unable to negotiate an agreement on Pillar One that they have felt able to adopt and bring before the U.S. Congress.

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