London Daily

Focus on the big picture.
Wednesday, Nov 04, 2026

Why the new global tax regime is unlikely to be clear, simple or good

Why the new global tax regime is unlikely to be clear, simple or good

Meant to extract more tax from the world’s richest multinationals, the proposed tax rules are already being strangled by talk of caveats and carve-outs. In short, the new rules would probably make little difference to total government revenues.

The headline writers make it all sound so clear, simple and good: “World’s leading economies agree on global minimum corporate tax rate” said the Financial Times.

In truth, the tax plan is more likely to be messy, strangled by caveats and carve-outs, and a veritable feast for tax avoidance experts. At worst, it will crash and burn. At best, it seems likely to have little impact either on the taxes that companies pay or the revenues that cash-strapped governments hope to pick up.

This practical reality has not suppressed the breathless excitement after Group of 7 leaders provided a critical push to the long-wrangled initiative at their summit in Cornwall, Britain. The Financial Times said the proposed tax reforms should be “genuinely considered historic” and that they would “change a century’s worth of tax rules to ensure the largest multinationals pay more tax where they operate”.

However, the newspaper’s European economics commentator Martin Sandbu argued that the outcome “is mixed at best” and that “governments have missed an opportunity to simplify the rules, leaving fertile ground for new and clever techniques to circumvent their intention”.

The same newspaper’s economic team was even more underwhelmed: “If some of the most powerful multinationals have had a bomb put under them, you wouldn’t know it from their reactions – or those of investors.”

Britain’s Chancellor of the Exchequer Rishi Sunak speaks at a meeting of G7 finance ministers at Lancaster House in London on June 4, ahead of the Cornwall summit, where leaders agreed on a minimum corporate tax rate proposal.


Their report said “the plan could upend some of the corporate world’s most widely-used avoidance strategies, while also throwing up a complex new set of rules for tax planners to get their teeth into”.

Scratch the surface of the proposed new tax rules, which had their origins in European frustration over the small tax payments made by the world’s most profitable technology groups, and you crash into complexity.

The proposed deal comprises two pillars. Most analysts like to tackle the second pillar first: a plan to set a minimum corporate tax rate worldwide at 15 per cent. That sounds straightforward, but it is not. For starters, there is serious dispute over whether the minimum tax rate should be set higher, perhaps up to 25 per cent.

The minimum rate would apply only to the world’s 100 largest multinationals, with turnover exceeding US$20 billion. There are already carve-outs for financial services and natural resources, and more battles over other carve-outs can be expected.

Taking the Fortune Global 500 list as an indicator of the companies likely to be targeted, you find that over 20 mainland Chinese companies sit in the top 100. But most of these are heavily focused on China’s domestic economy. International business accounts for little of their revenue. Unsurprisingly, most are unconcerned by the new tax plans, and the Chinese government has been relaxed about signing up.

Multinationals will only be bound by the new rules if they have a pre-tax profit margin of over 10 per cent, which is likely to encourage companies to raise reinvestment to suppress profit margins.

Intriguingly, the G7 has decided that the highly-profitable Amazon Web Services will be subject to the new rules even though its parent reports profits below 10 per cent. But what kind of cat-and-mouse games are going to be played by other giant multinationals over where profits and losses sit between the parent and the subsidiaries? Tax advisers must already be rubbing their hands.

Andy Jassy, who took over as Amazon CEO in July, at an event in Las Vegas on December 5, 2019, when he was heading Amazon Web Services. AWS is Amazon’s cloud computing business.


As for the first pillar, which is focused on getting multinationals to pay taxes where they generate their revenue, rather than in the low-tax domiciles they so often select, the rules quickly become similarly obscure. The digital services tax introduced over the past year by governments such France and Britain to claw more taxes from the large US tech companies is promptly submerged.

Indeed, for the United States, dropping the digital services tax is likely to be a formal precondition of support for the new tax rules. At the end of the day, only 20-30 per cent of so-called residual profit above the 10 per cent threshold would be subject to tax in the countries where it is generated.

Even after endorsement of the plan at the G20 over the past weekend, there remains a long and difficult path ahead – not least, passage through a truculent US Congress. A meeting of 130 countries is to be called later in the year, and implementation will be 2023 at earliest.

If the new rules pass successfully, the main reason for this may be that for most economies, the changes make barely any difference. Look at where the US federal government gets most of its revenue, and corporate taxes account for a paltry 7 per cent. Individual taxes account for 50 per cent, and social insurance and payroll taxes 36 per cent. That perhaps explains why the Biden administration is pressing for corporate taxes to be raised to 28 per cent.


The picture in Britain is similar: 6 per cent of revenues last year came from corporate taxes, with 23.4 per cent from individual taxes, and 16 per cent from value-added tax.


Look at China and Hong Kong, and the picture is a little different: corporate taxes already accounted for 21.8 per cent of Chinese tax revenues in 2019, individual taxes 6 per cent and excise and value-added taxes 52.9 per cent. For Hong Kong, corporate taxes accounted for 24 per cent of revenues in 2020-21, land premiums 16 per cent, stamp duty 15.7 per cent, and individual taxes 13 per cent.

In short, the new rules would probably make little difference to total revenues, even with rising pressure on governments to raise more revenues as pandemic borrowings have to be paid down.

Perhaps it is naive or foolish to expect anything different. Governments worldwide remain ferociously independent-minded over how they can raise taxes, how much they raise, and how they spend. For them to allow new multilateral rules to fetter this jealously guarded power would be political suicide.

So it should be no surprise, despite the melodramatic headlines, that the new rules are likely to change little. Tax rules will remain monstrously complex. Tax “management” will remain endemic. Some things in life cannot change.

Newsletter

Related Articles

0:00
0:00
Close
Department for Energy Security and Net Zero Approves Construction of New North Sea Offshore Wind Hub
Northern Ireland Executive Finalizes Public Sector Pay Agreements Following Months of Inter-Agency Negotiations
Welsh First Minister Eluned Morgan Secures Cross-Party Support for Regional Clean Energy Infrastructure Bill
Competition and Markets Authority Launches Formal Investigation Into Dominant Artificial Intelligence Cloud Partnerships
United Kingdom Foreign Secretary David Lammy Concludes High-Level Diplomatic Mission to Washington and Ottawa
Scottish Government Announces Emergency Housing Investment Package to Address Escalating Urban Homelessness
Chancellor Rachel Reeves Finalizes Corporate Tax Adjustments Ahead of Upcoming Business Investment Summit
National Health Service England Unveils Emergency Winter Resilience Plan to Combat Projected A&E Overcrowding
Bank of England Monetary Policy Committee Votes to Hold Base Interest Rate Steady at Four Point Seven5 Per Cent
UK Gross Domestic Product Expands by Zero Point Four Per Cent in Third Quarter Driven by Resilient Services Growth
Northern Ireland Executive Agrees on Multi-Year Public Sector Pay Restructuring Framework at Stormont
Department for Transport Confirms Acceleration of Electric Vehicle Charging Infrastructure Rollout Along Strategic Motorways
Welsh Government Announces Emergency Funding Package to Support Agricultural Sector Facing Severe Weather Impacts
High Court Rules in Favor of Environmental Coalition Over Government Carbon Reduction Plan Deficiencies
Office for National Statistics Reports Stable Retail Sales Growth Supported by Strong Digital Commerce Volumes
Scottish First Minister John Swinney Secures Cross-Party Support for Renewable Energy Export Expansion
National Health Service Digital Reports Major Breakthrough in Reducing Elective Waiting Lists Across England
Chancellor Rachel Reeves Outlines Infrastructure Spending Reforms to Boost Regional Economic Growth Across Northern England
Bank of England Holds Baseline Interest Rate at Five Percent Amid Persistent Core Inflation Pressures
House of Lords Advances Representation of the People Bill to Modernize Electoral Law Ahead of General Election
Financial Markets and Private Equity Assess Tax and Corporate Realignment Following Recent Chancellor Budget Adjustments
Justice Committee Warns Legal Aid Is a Service in Managed Decline Due to Inadequate Government Funding Responses
Royal Navy Intercepts Russian Intelligence Vessel and Warships Across Intensive North Sea Operations
Business and Trade Committee Slams Government Policy on China as Fragmented and Lacking Strategic Direction
Home Secretary Shabana Mahmood Softens Immigration Plans Following Intensive Cabinet Backlash Over Settlement Timelines
Automotive Industry Data Reveals Continued Acceleration in Battery Electric Vehicle Registrations Across British Dealerships
High Court of England and Wales Rules on Landmark Legal Challenge Regarding Local Government Housing Mandates
Department for Energy Security and Net Zero Approves Expanded Offshore Wind Infrastructure Along Scottish Coastline
Competition and Markets Authority Launches Broad Investigation Into Artificial Intelligence Infrastructure and Cloud Partnerships
United Kingdom and European Union Launch High-Level Preparations for Bilateral Defense and Security Summit in Brussels
National Health Service England Unveils Emergency Workforce Reforms to Alleviate Winter Accident and Emergency Pressures
Chancellor Rachel Reeves Finalizes Autumn Budget Adjustments to Meet Fiscal Rules and Fund Public Services
Bank of England Prepares for Interest Rate Decision Amid Rising Bond Yields and Inflationary Pressures
House of Lords Begins Detailed Legislative Scrutiny of Representation of the People Bill and Cyber Security Laws
Metropolitan Police Detain More Than Three Hundred Individuals Following Large-Scale Demonstration Outside London Embassy
Home Office Prepares Stricter Residency Rules Requiring Vulnerable Migrants to Wait Decade for Settlement Rights
Professional Mental Health Bodies Demand Statutory Regulation for Counsellors and Psychotherapists
National Grid Confirms Construction of Britain's Largest Electrical Substation to Power Teesside Data Centre
Prime Minister Keir Starmer Travels to Samoa for Commonwealth Summit Amid Debates on Economic Cooperation and Reparations
Home Office Implements Enhanced Digital Border Controls and Visa Processing Systems at Major Airports
Office for National Statistics Reports Stable Employment Participation Rates Across Regional Labor Markets
Department for Business and Trade Announces Strategic Partnership to Secure Critical Mineral Supply Chains
Scottish Government Unveils Regional Economic Development Strategy to Boost Advanced Manufacturing in Glasgow and Dundee
Treasury Officials Review Taxation Frameworks and Capital Gains Rules Ahead of Autumn Budget Disclosures
National Health Service Leaders Warn of Winter Capacity Pressures Across Acute Care Facilities
Bank of England Prepares for Key Interest Rate Decision Amid Sticky Inflation and Fiscal Policy Pressures
Home Office Expands Border Security Operations and Intelligence Sharing With European Partners
Office for National Statistics Reports Modest Retail Sales Growth Ahead of Crucial Christmas Trading Season
Welsh Government Unveils Strategic Plan to Boost Regional Technology Innovation and Digital Skills Training
Department for Environment Food and Rural Affairs Implements New Agricultural Subsidies Framework for English Farmers
×