Revised OECD tax deal keeps 15% minimum, adds U.S. carve-outs critics say weaken enforcement

A revised international agreement on global corporate taxation will preserve a 15% minimum rate while exempting U.S. multinationals from key enforcement rules, the Organization for Economic Cooperation and Development (OECD) announced. The framework’s core remains intact, but critics argue the carve-outs will dilute enforcement and reduce expected revenues.

The deal, years in the making, is intended to curb the ability of large multinationals to shift profits to low-tax jurisdictions. While the OECD framework advances, the latest changes carve out protections for U.S.-based companies, prompting warnings from advocacy groups that the original objectives are being weakened.

In the United States, the shift comes as President Trump has signaled opposition to the pact. One of his first directives in his second term instructed the Secretary of the Treasury, the U.S. Trade Representative, and the U.S.

Permanent Representative to the OECD to notify the organization that any commitments made by the prior administration “with respect to the Global Tax Deal have no force or effect within the United States absent an act by the Congress adopting the relevant provisions of the Global Tax Deal.” That stance leaves domestic implementation contingent on congressional approval.

The OECD, a Paris‑based forum of 38 mostly wealthy countries, has led the effort to modernize international tax rules on two tracks, known as Pillar One and Pillar Two. Pillar One addresses where profits should be taxed, even without a physical presence. Pillar Two focuses on how much tax is paid by establishing a 15% global minimum corporate rate.

As of last year, more than 140 countries had, in theory, agreed to the two-pillar framework; until 2025, that included the U.S. The current revisions primarily affect Pillar Two and include exceptions tailored to the U.S.

“This deal risks nearly a decade of global progress on corporate taxation only to allow the largest, most profitable American companies to keep parking profits in tax havens,” said Zorka Milin, policy director at the FACT Coalition. “The Trump administration has chosen to prioritize maintaining rock-bottom taxes for big corporations to the detriment of ordinary Americans and our allies across the globe.” Milin added that while U.S.

multinational corporations remain among the most competitive and innovative globally, that success has not always translated into fair tax contributions. “While the U.S. government has defended this deal as a win for ‘tax sovereignty,’ it actually does nothing for the U.S.

public revenues. The best way to protect American companies from ‘extraterritorial taxation’ is not to demand special treatment, but to ensure that these companies pay their fair share at home.” Milin and Thomas Georges, the FACT Coalition’s policy officer, said the revised agreement preserves the basic structure of the global minimum tax but weakens some of its enforcement mechanisms.

With the 15% floor retained and U.S.-specific exceptions in place, the OECD process will move ahead internationally, while U.S. participation remains subject to congressional action and debate over the scope of enforcement continues.