At a meeting of the G7 finance ministers in London from 4–5 June, it was agreed to adopt a minimum corporate tax rate of 15% and to take measures to prevent multinational companies using tax havens to avoid paying taxes. It was also agreed that part of the taxes paid should go to the countries where sales are made and not just to those where the companies are based.
This agreement is the first step on the road to a comprehensive global agreement. The next step is a meeting of the finance ministers and central bank governors of the G20 countries in Venice from 9 to 10 July. The G7 ministers hope that their agreement will be adopted by this larger group, which includes other major economies such as Russia, China, India, Brazil, Australia, South Korea and South Africa.
Later in July, the proposals will be put to a group of 139 countries and jurisdictions at a meeting co-ordinated by the OECD. It is hoped that this meeting will finalise an international agreement with precise details on corporate tax rules. It follows work by the OECD on reforming international taxation under its Framework on Base Erosion and Profit Shifting (BEPS).
These meetings follow growing concerns about the ability of multinational companies to avoid taxes by basing regional headquarters in low-tax countries, such as Luxembourg or Singapore, and declaring their profits there, despite having only a tiny proportion of their sales in these countries.
The desire to attract multinational profits has led to a prisoners’ dilemma situation, whereby countries have been competing against each other to offer lower taxes, even though it reduces global corporate tax revenues.
With many countries having seen a significant rise in government deficits as result of the COVID-19 pandemic and the support measures put in place, there has been a greater urgency to reach international agreement on corporate taxes. The G7 agreement, if implemented, will provide a significant increase in tax revenue.
Details of the G7 agreement
The agreement has two parts or ‘pillars’.
Pillar 1 allows countries to tax large multinationals earning global profits of more than 10% if these companies are not based there but earn revenues there. Countries will be given tax rights over at least 20% of the profits earned there which exceed the 10% margin. The level of profits determined for each country will be based on the proportion of revenues earned there.
Pillar 2 sets a minimum corporate tax rate of 15% for each of the seven countries, which call on other countries to adopt the same minimum. The hope is that the G20 countries will agree to this and then at the OECD meeting in July a global agreement will be reached. If a country chooses to charge a rate below 15%, then a top-up tax can be applied by the home country to bring the total rate up to the 15%.
It is possible that these proposals will be strengthened/amended at the G20 and OECD meetings. For example, the 15% minimum rate may be raised. Indeed, the USA had initially proposed a 25% rate and then 21%, and several EU countries such as France, have been pushing for a substantially higher rate.
Analysis
The agreement was hailed as ‘historic’ by Rishi Sunak, the UK Chancellor of the Exchequer. This is true in that it is the first time there has been an international agreement on minimum corporate tax rates and locating part of tax liability according to sales. What is more, the rules may be strengthened at the G20 and/or OECD meetings.
There have been various criticisms of the agreement, however. The first is that 15% is too low and is well below the rates charged in many countries. As far as the UK is concerned, the IPPR think tank estimates that the deal will raise £7.9bn whereas a 25% rate would raise £14.7bn.
Another criticism is that the reallocation of some tax liabilities to countries where sales are made rather than where profits are booked applies only to profits in excess of 10%. This would therefore not affect companies, such as Amazon, with a model of large-scale low-margin sales and hence profits of less than 10%.
Also there is the criticism that a 20% reallocation is too low and would thus provide too little tax revenue to poor countries which may record large sales but where little or no profits are booked.
The UK was one of the more reluctant countries to sign up to a deal that would have a significant impact on tax havens in various British overseas territories and crown dependencies, such as the British Virgin islands, Bermuda, the Cayman Islands, the Channel Islands and Isle of Man. The agreement also calls into question whether the announced UK freeports can go ahead. Although these are largely concerned with waiving tariffs and other taxes on raw materials and parts imported into the freeport, which are then made into finished or semi-finished products within the freeport for export, they are still seen by many as not in the spirit of the G7 agreement.
What is more, the UK has been pushing for financial services to be exempted from Pillar 1 of the deal, which would otherwise see taxes partly diverted from the UK to other countries where such firms do business. For example, HSBC generates more than half its income from China and Standard Chartered operates mostly in Asia and Africa.
Update: July 2021
The G7 plan was agreed by the finance ministers of the G20 countries on July 11 in Venice. By that point, 130 of the 139 countries which are part of the Inclusive Framework of the OECD and which represent more than 90% of global GDP, had signed up to the plan and it was expected that there would be a global agreement reached at the OECD meeting later in the month. The other nine countries were Ireland, Hungary and Estonia in the EU and Kenya, Nigeria, Peru, Sri Lanka, Barbados and Saint Vincent and the Grenadines. Several of these countries use low corporate taxes to encourage inward investment and are seen as tax havens.
Videos
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- Global Tax Deal: Historic agreement signed by G7 leaders
- Understanding tax avoidance
Channel 4 News, Helia Ebrahimi (5/6/21)
DW News, Alex Cobham (5/6/21)
WION on YouTube (5/6/21)
OECD
Articles
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- Explainer: G7 tax deal – what was agreed and what does it mean for Ireland?
- G7 deal: UK is badly conflicted between offshore tax havens and Biden’s global tax drive
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- UK pushes for City of London to be exempt from G7 tax plan
- The global pandemic, sustainable economic recovery, and international taxation
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CNBC, Silvia Amaro, Joanna Tan and Emma Newburger (5/6/21)
The Telegraph, Lucy Burton and Edward Malnick (5/6/21)
CNN, Tara John and Kevin Liptak (5/6/21)
Sky News, Ajay Nair (6/6/21)
New York Times, Alan Rappeport (5/6/21)
Financial Times, Chris Giles (5/6/21)
LAPM Journal, Chris Giles and Delphine Strauss (FT) (6/6/21)
BBC News (6/6/21)
The Observer, Phillip Inman and Michael Savage (5/6/21)
The Guardian, Richard Partington (6/6/21)
The Guardian, Jasper Jolly (6/6/21)
The Irish Times, Cliff Taylor (5/6/21)
The Conversation, Atul K. Shah (4/6/21)
Independent, Emily Goddard (6/6/21)
The Guardian, Phillip Inman and Richard Partington (9/6/21)
Independent Commission for the Reform of International Corporate Taxation (May 2020)
BBC News (11/7/21)
Questions
- How are multinationals currently able to avoid paying corporate taxes in many countries, even though their sales may be high there?
- If the deal is accepted at the OECD meeting in July, would it still be in the interests of low-tax countries to charge tax rates below the agreed minimum rate?
- Why was the UK reluctant to accept the 21% rate proposed by the Biden administration?
- Find out about the digital services tax that has been adopted by many countries, including EU countries and the UK, and why it will be abolished once a minimum corporate tax comes into force.
- Argue the case for and against taxing the whole of multinational profits in countries where they earn revenue in proportion to the company’s total global revenue. Would such a system benefit developing countries?
- Should financial services, such as those provided by City of London firms, be exempted from the deal?
In his March 2021 Budget, Rishi Sunak announced the setting up of eight freeports in England. These will be East Midlands Airport, Felixstowe & Harwich, Humber, Liverpool City Region, Plymouth and South Devon, Solent, Teesside and Thames. The locations were chosen after a bidding process. Some 30 areas applied and they were judged on various criteria, including economic benefits to poorer regions. Other freeports are due to be announced in Scotland, Wales and Northern Ireland. The Scottish government 
Freeports are treated as ‘offshore’ areas, with goods being allowed into the areas tariff free. This enables raw materials and parts to be imported and made into finished or semi-finished products within the freeport area. At that stage they can either be imported to the rest of the country, at which point tariffs are applied, or they can be exported with no tariff being applied by the exporting country, only the receiving country as appropriate. This benefits companies within the freeport area as it simplifies the tariff system.
Then there is the question of whether such areas are in breach of international agreements. WTO rules forbid countries from directly subsidising exports. And the Brexit trade deal requires subsidies to be justified for reasons other than giving a trade advantage. If the UK failed to do so, the EU could impose tariffs on such goods to prevent unfair competition.