KPMG report: “Amsterdam Dialogue on Global Minimum Tax Compliance” stakeholder meeting, October 2025
Policy issues that remain unresolved and on which further OECD guidance is likely required
In November 2024, the OECD Forum on Tax Administration (FTA)—a forum that brings together over 50 OECD and non-OECD tax administrations—established the “Amsterdam Dialogue on Global Minimum Tax Compliance” following a joint seminar hosted by the OECD and the Dutch Tax Administration (hence, the “Amsterdam Dialogue”).
The objective of the Amsterdam Dialogue is to improve coordination and consistency in the administration of the global minimum tax (GMT), and thus it plays an important role in broader efforts to simplify Pillar Two. This was recently recognized in the OECD Secretary-General’s Tax Report to G20 Finance Ministers and Central Bank Governors, which was published earlier this month. Read TaxNewsFlash
The second meeting of the Amsterdam Dialogue was held in Manchester, UK, on October 27 and 28, 2025. On the first day, tax administration officials and business stakeholders discussed various aspects of GMT implementation, split across three sessions:
- State of play and ongoing work in implementation and administration: Providing an update on the global implementation of the GMT
- Applying the GMT – addressing compliance challenges: Discussing some of the challenges associated with registration and filing, applying safe harbors, and completing the global information return (GIR)
- Applying the GMT – ensuring coordination and consistency: Discussing some of the emerging issues arising from differences between country-level registration and filing requirements, and the interpretation and application of the GMT
The second day was a closed-door meeting, where OECD and tax officials continued discussions, presumably including their reflections on the first day’s meeting.
Key insights and takeaways
The discussions were wide-ranging, but some of the key insights and takeaways include:
- Safe harbors: While not the primary focus of the session, the OECD Secretariat repeatedly emphasized that work on the simplified effective tax rate (ETR) safe harbor was progressing and indicated that an agreement was possible by the end of the year. It was also suggested that consideration was being given to extending the transitional country-by-country (CbC) reporting safe harbor.
- Joint ventures (JVs) and partially-owned parent entities (POPEs): Business stakeholders emphasized the challenges they were facing in applying the rules for JVs and POPEs. For JVs, it was noted that even collecting the data required to apply the JV rules could be challenging, while for both JVs and POPEs, businesses were having difficult conversations with minority owners about how to allocate the cost of any top-up tax incurred.
- Mergers and acquisitions (M&A): Business stakeholders discussed the challenges that M&A activity can create for Pillar Two. When targets are acquired, they immediately become part of a group’s Pillar Two group, but may not be incorporated into a group’s accounting systems, making it difficult (and potentially impossible) to obtain the data required to undertake the necessary Pillar Two computations.
- Transfer pricing and post-year-end tax adjustments: Business stakeholders cited the inconsistency and uncertainty about these issues as an area of significant concern that should be addressed through further administrative guidance.
- Hyperinflationary currencies: Business stakeholders noted that unintended top-up tax liabilities could arise in respect of countries with hyperinflationary currencies, such as Argentina and Turkey. It was noted that this was an issue the OECD Secretariat was aware of and actively working on.
- Early certainty and dispute prevention and resolution: Tax administrations sought businesses’ views on the most effective way to provide early certainty over the GMT and to prevent and resolve disputes. It was noted by one business stakeholder that the relative objectivity of the GMT rules, in comparison to transfer pricing, meant that hopefully tax certainty could be provided more quickly than for transfer pricing.
Next steps
The discussions in Manchester highlight that while businesses’ and tax administrations’ attention is turning towards compliance—with Belgium’s qualified domestic minimum tax (QDMTT) return due in just over a month—there are still a lot of policy issues that remain unresolved and on which further OECD guidance is likely required.
For more information, contact a KPMG tax professional:
Alistair Pepper | alistairpepper@kpmg.com