Jan 5, 2026
Global Tax Coordination Developments in 2025
In 2025, historic progress was made in global tax coordination, particularly through the implementation of the Global Minimum Tax agreed under the OECD framework (Pillar Two). Starting with the 2025 fiscal year-end, multiple jurisdictions, from the European Union to Latin American economies, adopted legislation to ensure that large multinational groups, with consolidated revenues exceeding €750 million, pay an effective tax rate of at least 15% in each country where they operate.
Implementation of the Global Minimum Tax (Pillar Two)
For example, countries such as Spain and Uruguay approved a top-up minimum tax aligned with Pillar Two, aimed at collecting additional taxes from multinationals currently taxed below the 15% threshold, preventing those tax revenues from accruing solely to the group’s headquarters jurisdiction.
Although effective cash payments are expected to begin in 2026–2027, this measure already impacts 2025 financial closings, as potentially affected companies must assess and recognize provisions for this new tax in their financial statements. Uruguay alone is estimated to collect between US$300 and US$350 million annually from this measure.
Status of Pillar One and Digital Services Taxes
Meanwhile, Pillar One of the global agreement, which seeks to reallocate a portion of multinational digital companies’ profits to market jurisdictions, failed to achieve full consensus in 2025, delaying its implementation.
As a result, several countries continue to apply unilateral Digital Services Taxes while awaiting a multilateral solution.
International Outlook for 2026
Looking ahead to 2026, the international trend points toward greater cooperation to combat tax evasion and harmful tax competition, consolidating tools such as automatic exchange of financial information and double taxation avoidance agreements. However, progress will depend on political will and coordination among major economies.