Global Daily Tax News, G20 Leaders Discuss Pillar Two State Of Play In South Africa, (Nov 25, 2025)

G20 leaders agreed a number of priorities in the area of international tax reform, in a declaration released following their November 22, 2025, summit in South Africa.

The Declaration states: "We will continue engaging constructively to address concerns regarding Pillar Two global minimum taxes, with the shared goal of finding a balanced and practical solution that is acceptable for all as soon as possible. Delivery of a solution will need to include a commitment to ensure any substantial risks that may be identified with respect to the level playing field, including a discussion of the fair treatment of substance-based tax incentives, and risks of base erosion and profit shifting (BEPS), are addressed and will facilitate further progress to stabilize the international tax system, including a constructive dialogue on the tax challenges arising from the digitalisation of the economy. These efforts will be advanced in close cooperation across the membership of the OECD/G20 Inclusive Framework (IF), preserving the tax sovereignty of all countries."

"We note the ongoing negotiations to establish a United Nations Framework Convention on International Tax Cooperation, and the participating G20 members reaffirmed the objectives to reach a broad consensus and build on existing achievements, processes and the ongoing work of other international organisations, while seeking to avoid unnecessary duplication of efforts."

"Recalling the G20 Rio de Janeiro Ministerial Declaration on International Tax Cooperation, we continue to welcome the IF's decision to adopt a phased, evidence-based approach to explore global mobility and to understand the interaction between tax policy, inequality, and growth."

"We welcome the stocktake reports on the OECD/G20 BEPS Project and transparency initiatives, which demonstrate that significant progress can be made from working together. Building on the gains and ensuring that developing countries can fully participate and benefit will require supporting inclusive participation and enhancing tax capacity tailored to needs. There is an opportunity to expand on these gains with a new OECD framework that will enable interested jurisdictions to strengthen international tax transparency on immovable property on a voluntary basis."

The Declaration concludes: "We agree that Domestic Resource Mobilisation (DRM) is a shared imperative. The deliverables under the South African G20 Presidency demonstrate that DRM is the most effective funding source, revenue administration is an essential pillar of the tax system, coordination and collaboration among capacity-building providers are important, and a structured approach to reform – country-owned, country-led, fulfilling the social contract with taxpayers – is valuable. We look forward to the Platform for Collaboration on Tax (PCT) Tax and Development Conference on DRM in Tokyo next year."