经济合作与发展组织秘书长向G20财长和央行行长提交的税务报告（G20南非，2025年2月）

G20South Africa,February 2025 OECD Secretary-General Tax Report to G20Finance Ministers and Central BankGovernors G20 South Africa, February 2025 This document and any map included herein are without prejudice to the status of or sovereignty over any territory, tothe delimitation of international frontiers and boundaries and to the name of any territory, city or area. This work is published under the responsibility of the Secretary-General of the OECD. The opinions expressed andarguments employed herein do not necessarily reflect the official views of OECD member countries. Please cite this publication as: OECD (2025),OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (G20 South Africa, February 2025), OECDPublishing, Paris,https://doi.org/10.1787/97afc9f7-en. Table of contents Introduction4Support for G20 Initiatives5Two-Pillar International Tax Package6BEPS Update9Transfer Pricing12Tax and Inequality12Tax Certainty13Digital Transformation14Tax Policy tools14Tax and Development15Global Forum on Transparency and Exchange of Information for Tax Purposes18 Introduction Ahead of the first G20 Finance Ministers’ and Central Bank Governors’ meeting under the South AfricanG20 Presidency, I am pleased to report to you on key tax developments since my last report to you inOctober 2024. TheSouth African presidency of the G20has set out an ambitious agenda focusing on itsprioritythemes of solidarity, equality, and sustainability. The OECD is committed to working with South Africaand other G20 members to deliver on a suite of reports on international tax co-operation issues to mobilisedomestic resources, enhance tax certainty, and tackle inequality. I also will provide regular reports onlongstanding G20 priorities such as tax transparency, addressing base erosion and profit shifting (BEPS),and the Two‐Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economyagreed in October 2021. Since you last met, the Co-Chairs of the G20/OECD Inclusive Framework on BEPS issued anupdate onthe progress in the development of a final package for Pillar One1of the Two-Pillar Solution. Thispackage includes two components: a text of the Multilateral Convention (MLC) to implement Amount Aand a linked framework for Amount B. The statement acknowledged the significant progress made in 2024to resolve a small number of disagreements on the MLC text. Consequently, the text has remained stable,with only one jurisdiction objecting to the text’s adoption in June 2024. Since that point, the negotiationshave been focused on resolving the outstanding issues with the Amount B Framework, which have alsomade significant strides in recent months as only a few outstanding issues remain amongst certainjurisdictions. The ongoing implementation oftax transparency standards around the globe continues to deliveroutstanding results for member jurisdictions of the Global Forum on Transparency and Exchange ofInformation for Tax Purposes. The Global Forum’s November 2024 plenary saw the adoption of additionalstandardson reporting of crypto-assets, with 66 jurisdictions now agreeing to begin exchange ofinformation in 2027 or 2028, and 48 jurisdictions already beginning to implement their commitment bysigning the CARF Multilateral Competent Authority Agreement in November 2024. The common approach to establishing a global minimum tax under Pillar Two continues to draw interestfrom a broad range of developed, emerging, and developing economies. As of January 2025, there are 55jurisdictions that have already enacted or introduced legislation to implement the Global Anti-Base Erose(GloBE) rules. A further 10 jurisdictions have taken concrete steps toward implementation. Support for G20 Initiatives The OECD is pleased to contribute its expertise on tax and fiscal policy matters in support of the ambitiouswork programme set out by the South African presidency of the G20 by leveraging our resources inproviding data-driven, evidence-based policy research. As outlined in greater detail further below, the OECD will support the G20/OECD Inclusive Framework onBEPS (Inclusive Framework) in its consideration of the interaction of tax policy, inequality, and growth. Byrelying on data and economic analysis, and by facilitating the sharing of experiences on domestic policytools, this work will provide research to inform future political discussions by member governments. Yourinvitation to the Inclusive Framework follows from your statement last July and builds on a report2preparedby the OECD examining interactions between taxation and inequality by exploring how tax systems canmitigate or exacerbate inequality and identifying scope for potential reforms. The Inclusive Framework willtake this issue up at its next Plenary meeting in April. The OECD will support the Inclusive Framework in undertaking a broad-based stock-take to look at theprogressand impact of international co-operation over the p