Nigeria, 146 Others Agree Way Forward on Global Minimum Tax Package

Ndubuisi Francis in Abuja

Nigeria and 146 other countries, as well as jurisdictions working together within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS), have agreed on key elements of a package that charts a way forward for the coordinated operation of global minimum tax arrangements in the context of a digitalised and globalised economy.

Following months of intense negotiations, the comprehensive package for a “side by side” arrangement, announced yesterday, represents a significant political and technical agreement, which will set the foundation for stability and certainty in the international tax system.

Domestic tax base erosion and profit shifting (BEPS) relates to tax planning strategies that multinational enterprises use to exploit loopholes in tax rules to artificially shift profits to low or no-tax locations as a way to avoid paying tax.

The OECD/G20 BEPS Project equips governments with rules and instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating them take place and where value is created.

The agreed package will preserve the gains achieved so far in the global minimum tax framework and protect the ability for all jurisdictions, particularly developing countries, to have first taxing rights over income generated in their jurisdictions.

The package includes five key components:

First, a series of simplification measures will reduce compliance burdens for multinational enterprises (MNEs) and tax authorities in calculating and reporting under the global minimum tax rules.

Second, the package further aligns the treatment of tax incentives globally through the introduction of a new targeted substance-based tax incentive safe harbour.

Third, new safe harbours are available to MNE Groups having an ultimate parent entity located in an eligible jurisdiction, which meets minimum taxation requirements.

Fourth, the package includes an evidence-based stocktake process to ensure a level playing field is maintained for all Inclusive Framework Members.

The package also reinforces the objective that qualified domestic minimum top-up tax regimes remain a primary mechanism in the global minimum tax framework for ensuring the protection of local tax bases, particularly in developing countries.

“This agreement by the Inclusive Framework including 147 countries and jurisdictions is a landmark decision in international tax co-operation,” OECD Secretary-General, Mathias Cormann said.

Cormann added, “The Members of the Inclusive Framework are to be commended for their work in finalising this package, which enhances tax certainty, reduces complexity, and protects tax bases. I look forward to seeing the Inclusive Framework take forward the implementation of this package, as well as to future proposals for further simplifications of the global minimum tax rules and compliance burdens.”

Additional tools and fact sheets to support the implementation of the package will be made available in the coming weeks, alongside a dedicated webinar hosted by the OECD on January 13, 2026.

The OECD will also continue to ensure that the rules can be implemented effectively and efficiently by all countries and jurisdictions, offering comprehensive capacity-building assistance where needed.