G7 Nations Agree to Exempt U.S. Firms from Global Minimum Tax

In a significant policy shift, the Group of Seven (G7) nations have agreed to exempt U.S. multinational companies from the global minimum tax framework, offering them a special “side-by-side” taxation solution. The arrangement, pushed by U.S. President Donald Trump’s administration, will ensure that American corporations are taxed solely by the United States on both domestic and foreign profits, potentially reshaping the global tax architecture negotiated under the OECD framework since 2021.

Why in News?

On June 28, 2025, the G7 released a joint statement, under Canada’s presidency, confirming an exemption for U.S. multinational firms from the 15% global minimum tax. This follows Trump’s efforts to alter international taxation laws through his domestic policy reforms and intense diplomatic negotiation. The decision aligns with proposed changes in the U.S. tax code and indicates a major deviation from the OECD-led global tax consensus of 2021.

Background and Context

  • In 2021, around 140 countries, under the OECD, agreed on a two-pillar global tax deal.
  • Pillar One: Reallocates taxing rights on large multinationals.
  • Pillar Two: Imposes a 15% global minimum corporate tax to prevent tax base erosion.
  • The U.S. had opposed parts of this agreement, especially under Trump’s leadership, citing sovereignty concerns and business competitiveness.

What the G7 Agreement Includes

  • U.S. companies will now be taxed exclusively in the United States — not in the jurisdictions where they operate.
  • This is termed a “side-by-side” model.

The arrangement offers,

  • Tax stability and reduced compliance complexity.
  • Increased foreign investment appeal for U.S. businesses.
  • Strategic shielding from double taxation.

Key Points

  • Exemption Not Finalized: The OECD still needs to approve this exemption.
  • Trump’s Policy Push: The “One, Big, Beautiful Bill”, Trump’s mega-domestic policy bill, contains major international tax revisions.

Section 899 Controversy

  • Allows taxing of foreign investors/owners if their home countries are seen as imposing unfair taxes.
  • Dubbed a “revenge tax”, raising concerns of retaliatory trade barriers.

Global Implications

  • Could undermine global tax cooperation efforts.
  • Might trigger similar exemptions or unilateral policies by other countries.
  • Risks creating a two-track global tax regime, affecting fair competition.

Static Facts

  • G7 Members: Canada, France, Germany, Italy, Japan, the U.K., and the U.S.
  • OECD: Organisation for Economic Co-operation and Development – a group of 38 nations working on global standards and policies.
Shivam

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