Among the signatories to the agreement, among others are the 10 most important global economies: the United States of America. China, Japan, Germany, UK, France, India, Italy, Brazil and South Korea.

According to a report by the Polish Economic Institute (PIE), the CIT reform will bring $115 billion from public budgets.

This is the beginning of the global tax revolution. This large number of support for solutions prepared by the Organization for Economic Co-operation and Development illustrates the urgency of the problem in shifting profits, unfair distribution of tax revenues, or the operation of tax havenssays Piotr Arak, Director of PIE.

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Who will benefit from the first pillar?

The approved solutions consist of two so-called pillars. The first is the taxation of the largest multinational companies whose consolidated annual revenue exceeds 20 billion euros.

Among them, those with profit margins above 10 percent. (about 100 companies worldwide) would have to split 20% to 30%. Their global income is among the countries in which they sell their services and products.


The beneficiaries of the first pillar are the countries with the largest consumer base (primarily the largest of the European Union, the United Kingdom). Thanks to the reallocation of taxes, its tax revenue will increase significantly – estimates Łukasz Błoński, a PIE analyst.

Who will benefit from the second pillar?


After this solution takes effect, international companies that are taxed in a particular country below the minimum threshold will be subject to an additional tax in the home country, up to 15%. At the same time, a solution was adopted and supported, among other things, by Poland, according to which companies engaged in real economic activity in a particular country were excluded from tax.

Upon entering the Pillar II life, countries with headquarters for international companies eligible for a minimum CIT will benefit. With the tax havens gone, the profits of these companies will be taxed in their jurisdictions – وفقukasz Błoński estimates.

The OECD assumes that in July this year the G20 should approve the solutions developed, and by the fall all additional details will be worked out, allowing global solutions to be adopted in 2023.


The introduction of a minimum CIT requires changes in legislation only at the national level, but for the tax solutions described under Pillar I to take effect, it is necessary to change international treaties.

For this, the support of all countries of the world is necessary. Nine countries (Barbados, Estonia, Hungary, Ireland, Kenya, Nigeria, Peru, Sri Lanka, Saint Vincent) did not agree to accept the proposed solutions, which means that further international negotiations are needed in this regard.