A detailed implementation plan together with remaining issues will be finalised by October 2021
Under the plan, countries will be able to tax the profits of large companies in markets where they are earned regardless of whether they have a physical presence there, while a global minimum tax rate of at least 15% will be set.
The OECD said the plan will ensure that multinational enterprises pay a fair share of tax wherever they operate.
The agreed statement represents a significant development in a long reform process that has been led by the OECD over the past two years and involved 139 states.
Nine countries including Ireland, Estonia and Hungary, that had been part of the discussions have not yet signed up to plan, the OECD said in a statement.
But those that have represent 90% of global GDP, and include the US, China, the UK, France and Germany.
“The remaining elements of the framework, including the implementation plan, will be finalised in October,” the OECD said.
Minister for Finance Paschal Donohoe had previously said that the Government wanted to be part of any agreement on global corporation tax reform.
Ireland stands to lose up to €2.4bn in tax revenue over the next four years as a result of the changes.
“After years of intense work and negotiations, this historic package will ensure that large multinational companies pay their fair share of tax everywhere,” OECD Secretary-General Mathias Cormann said.
“This package does not eliminate tax competition, as it should not, but it does set multilaterally agreed limitations on it.”
The OECD said the two-pillar package would ensure large firms pay tax where they operate and earn profits while also adding certainty and stability to the global tax system.
Under the first pillar, taxing rights on more than $100bn of profit are expected to be reallocated from companies’ home markets to other jurisdictions every year.
Companies considered in scope would be multinationals with global turnover above €20bn and a pre-tax profit margin above 10%, with the turnover threshold possibly coming down to €10bn after seven years following a review.
Extractive industries and regulated financial services are to be excluded from the rules on where multinationals are taxed.
While the minimum tax rate of at least 15%, agreed under pillar two, is expected to yield up to $150bn in additional revenue every year, the OECD said.
The rate would apply to companies with turnover above a €750m threshold, with only the shipping industry exempted.
However, the Irish Government had been resistant to the setting of a global minimum tax rate above its current 12.5% rate because it could take away its competitive edge for foreign direct investment.
But the OECD has claimed that the plan would provide much needed revenue for Governments, as well as yield stability in the international tax system and increase tax certainty for taxpayers and administrators.
“It also accommodates the various interests across the negotiating table, including those of small economies and developing jurisdictions,” said Mr Cormann.
It is hoped the plan will be ready for implementation in 2023.
Minister for Finance Paschal Donohoe
“Overall pillar one will bring stability and certainty to the international tax framework and will help underpin economic growth from which all can benefit,” it said.
The Department said that Ireland expressed “broad support” for the agreement on pillar two, but noted reservation about the proposal for a global minimum effective tax rate of at least 15%.
“As a result of this reservation, Ireland is not in a position to join the consensus,” the statement read.
Minister for Finance Paschal Donohoe said that Ireland will “constructively engage” in further discussions and technical work over the coming months.
“I have consistently spoken of my desire for a comprehensive, sustainable and equitable agreement on the international tax rules at the OECD that meet the needs of all countries, large and small, developed and developing,” he said.
“I was not in a position to join the consensus on the agreement and specifically a global minimum effective tax rate of ‘at least 15%’ today.
“I have expressed Ireland’s reservation, but remain committed to the process and aim to find an outcome that Ireland can yet support. Ireland will continue to play our part in reaching a comprehensive and, indeed, historic agreement,” he said.
The Minister later told a press conference that a public consultation on the plan would now be launched here with a view to gathering views ahead of the finalisation of the plan in October.
Mr Donohoe declined to say in what way the pillar 2 plan could be changed to make it acceptable to Ireland, saying negotiations were ongoing.
Asked about the potential reputational risk of Ireland not signing up from the start, Mr Donohoe said it will only be possible to form a view on the effects of being in the agreement or not when the point of implementation is reached.