Analysis of commitment data show concrete steps that the G20 can take towards improving compliance on international corporate taxation
Since its first meeting in Washington in 2008, the G20 has played a pivotal role reforming international corporate taxation. To launch Base Erosion and Profit Sharing 1.0, the Los Cabos Summit in 2012 tasked the Organisation for Economic Co-operation and Development with creating and implementing an action plan that would equip governments with domestic and international rules and instruments to address corporate tax avoidance. This culminated in the Inclusive Framework on BEPS, whose current 139 members represent more than 95% of global gross domestic product. In July 2021 G20 finance ministers endorsed BEPS 2.0, to address the tax challenges of the digitalisation of the economy. As they called for an agreement and detailed implementation plan by October 2021, the Rome Summit is poised to be a watershed moment for the reform of the international corporate tax regime.
G20 leaders have addressed international taxation at every summit since the start in 2008, dedicating 13,114 words (6%) to the subject in their outcome documents. The portion of words ranged from a record low of 1% at Washington in 2008 to a record high of 16% at the St Petersburg Summit in 2013, which uniquely produced a document dedicated to international taxation. Then Brisbane in 2014 produced 3%, followed by 4% at Antalya in 2015, 8% at Hangzhou in 2016 and 3% at Hamburg in 2017. This rose to 10% at Buenos Aires in 2018, then dropped to 3% each at Osaka in 2019 and Riyadh in 2020.
These conclusions contained 134 collective, politically binding, future-oriented commitments on international taxation, or approximately 4% of the total on all subjects. They averaged nine commitments per summit. Their portion ranged from a peak of 25 commitments, taking a portion of 9% at St Petersburg in 2013, to a low of two commitments (2%) at Pittsburgh in 2009.
Of these 134 tax commitments, 30 have been assessed for compliance by the G20 Research Group. They averaged 76% compliance, well above the G20’s overall average of 71%. Compliance was highest following the Antalya Summit in 2015 at 90%, where leaders committed to enhance tax transparency by reaffirming previous commitments on the automatic exchange of tax information. Compliance was 84% for Washington in 2008 and Hangzhou in 2016. St Petersburg in 2013 had the lowest, at 61%. Other lows were Cannes in 2011 and Osaka in 2019, both with 65%.
Causes of compliance
The relationship between the proportion of conclusions on international taxation at each G20 summit and overall compliance shows a positive but weak correlation coefficient of +0.07. The relationship between the proportion of commitments dedicated to international taxation and overall compliance similarly shows a positive but still weak correlation coefficient of +0.20.
Of the 23 catalysts of instructions embedded in the text of commitments, overall compliance was strongly positively correlated with commitments that referred to a specified agency, the politically binding strength of the commitment’s verb and commitments that set a one-year timetable for completion. A subsequent multiple regression analysis found one statistically significant negative relationship between compliance outcomes and commitments that delegated to international organisations other than the OECD. This may imply that delegating commitments to institutions that are not core to international taxation may hinder compliance.
Since the COVID-19 pandemic emerged in December 2019, the world’s advanced economies have incurred record deficits while global markets have become increasingly digitalised, underscoring the need to tackle corporate tax avoidance and safeguard national treasuries from offshoring and tax base erosion. Moreover, the election of Joe Biden as US president and the endorsement by the G20 finance ministers of BEPS 2.0 have added considerable momentum to the international corporate tax reform agenda. Calls for finalising an agreement and detailed implementation plan this October suggest the Rome Summit could be pivotal for corporate tax reform. To increase compliance with the commitments made there, G20 leaders should, above all, express their commitments in strongly binding language, set an ambitious one-year timetable for their completion and delegate core tasks to the OECD.