57

A landmark deal, adopted in October 2021 by 137 countries and jurisdictions of the OECD/G20 Inclusive Framework on BEPS (for Base Erosion and Profit Shifting), completes the fight against aggressive tax optimisation by multinational enterprises. Based on a two-pillar solution, one changing the allocation of taxing rights between states and the other introducing a minimum tax rate on corporate profits, this agreement is the result of several years of negotiations and developments towards better regulation of international taxation. This paper describes the origins of this work and the main objectives and elements of the agreement adopted in 2021, as governments and the OECD now turn to its implementation.