经合组织秘书长向G20领导人提交的税务报告（G20南非，2025年11月）

G20South Africa,November2025 OECD Secretary-General Tax Reportto G20 Leaders G20 South Africa, November 2025 2| 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 Leaders(G20 South Africa,November 2025),OECD Publishing,Paris,https://doi.org/10.1787/54b70436-en. Table of contents IntroductionSupport for G20 Initiatives Introduction Ahead of the G20 Leaders’ Summit under the South African G20 Presidency, I am pleased to report to youon key tax developments since my last report to you in November 2024.1 The OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) is continuing discussions on theconcerns raised by the United States regarding US multinational enterprises (MNEs) being subject toduplicativetax systems and multiple taxation.On 28 June 2025,the G7 issued a statement ofunderstanding about a proposed “side-by-side” arrangement to preserve the gains achieved underPillar Two and provide greater stability in the international tax system through an outlined set of principles Inaddition,this report provides important updates on other key G20 tax priorities involving taxtransparency, continued implementation of the BEPS minimum standards, tax and development, support Support for G20 Initiatives The G20 has long supported international tax co-operation that improves transparency, reduces barriersto trade and investment, promotes growth, protects fiscal bases, and addresses development needs. TheOECD has worked for more than 15 years to support these priorities, including by providing data-driven,evidence-based policy research and by facilitating co-operation to deliver on specific policy initiativesendorsed by successive G20 presidencies. Key OECD tax policy initiatives prioritised and endorsed by the South Africa’s G20 Presidency in 2025 concludes the initial rotation of presidencies held by membercountries since the first G20 took place in 2008, providing an opportunity to reflect on past achievements In response to a request from the South African Presidency, the OECD prepared two reports this yeartaking stock of progress on BEPS and on tax transparency: •A Decade of the BEPS Initiative2: The Inclusive Framework has prepared a broad-based stocktakereport on the progress and impact of the BEPS Project over the past decade,using an evidence- basedapproach that shows the economic impact of the BEPS Actions and sharingrecommendations for future work.•Taking Stock of Progress on Transparency and Exchange of Information for Tax Purposes3: The Beyond progress on these core G20 priorities, the OECD also has responded to the request from theSouth African Presidency to address recent priorities on simplification, expanded information exchange forreal estate, and continued exploration of issues involving tax policy, inequality, and growth. The OECDreport delivered to the G20 in October 2025 included a report on an international framework to promoteadditional implementation of automatic exchange of readily available information regarding real estate, and The OECD also prepared and delivered a report to the Presidencyon identifying ways to simplifyinternational tax rules to make them easier to implement, particularly for developing countries, while also Finally, in April, the Inclusive Framework agreed to consider the interaction of tax policy, inequality, andgrowth, using an evidence-based, phased approach. By relying on data and economic analysis, and byfacilitating sharing experiences on domestic policy tools, this work will provide research to inform future Progress on the Implementation of the Global Minimum Tax The global minimum tax, which was agreed as part of the October 2021 agreement on the Two-PillarSolution to Address the Tax Challenges Arising from the Digitalisation of the Economy, aims tomitigateinvestment distortions and protect domestic tax bases, while improving certainty and stability for large To date, more than 65 jurisdictions have already implemented or taken concrete steps to implement theGloBE Rules or a Qualified Domestic Minimum Top-up Tax. In January 2025 the Inclusive Framework had released a central record of the legislation that has beenimplemented by members and which has secured qualified status under the transitional qualificationmechanism. This central record was updated in March 2025 and again on 18 August 2025 and now lists42 Qualified Income Inclusion regimes and 43 Qualified Domestic Minimum Top-up Tax regimes4. Thecentral record will continue to be updated on a regular and timely basis to i