The Intergovernmental Group of Twenty-Four (G-24) has issued a communiqué following a Ministers and Governors meeting held on 11 October 2022, including calls for the finalization of the subject to tax rule under Pillar 2, as well improvements to simplify the administration of the rules for emerging markets and developing economies (EMDEs). In this respect the communiqué states the following:
10. The introduction of a global minimum tax and taxation of the digital economy are welcome reform principles under the global tax deal agreed upon by the G20/OECD Inclusive Framework. We call for an early finalization of the subject to tax rule, which is an essential component of Pillar Two, with a broad scope covering services and capital gains, which remain base eroding concerns for EMDEs. In addition, the Two-Pillar solution should be simpler to administer and provide sufficient taxing rights for EMDEs. Going forward, building on the reform principles agreed upon in the Inclusive Framework, developing countries need to develop and implement tax measures, including withholding taxes, on digital and remote transactions involving their residents, or to configure a significant taxable economic presence in their jurisdictions to protect their tax base in ways that are tailored to their unique circumstances. This will entail a stronger and more inclusive multilateral cooperation to reach a fairer and more stable international corporate tax system that can yield meaningful revenues for EMDEs.
Note, the G-24 is currently comprised of 28 members, including Algeria, Argentina, Brazil, Colombia, Congo, Cote d’Ivoire (Ivory Coast), Ecuador, Egypt, Ethiopia, Gabon, Ghana, Guatemala, Haiti, India, Iran, Kenya, Lebanon, Mexico, Morocco, Nigeria, Pakistan, Peru, Philippines, South Africa, Sri Lanka, Syria, Trinidad and Tobago, and Venezuela. China is also a member, attending meetings as a "Special Invitee".