The US Treasury Department (Treasury) has proposed to the Steering Group of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) that the global corporate minimum tax rate (the Pillar Two) should be at least 15%. The Treasury announced this proposal in its Press Release dated 20 May 2021.
The 15% rate is lower than the 21% rate for which the Biden administration has been pushing as a new rate for the US global minimum tax on foreign earnings of US multinational corporations, i.e. the tax on global intangible low-taxed income (GILTI), which is currently set at 10.5%.
The Treasury underscored that 15% is a floor and that discussions should continue to raise the rate higher.
The IBFD will be tracking the proposal closely and report more on this as it develops.