Global Minimum Tax: American corporate groups may be permanently exempt from regulation

By: Trademagazin Date: 2025. 07. 14. 11:58

There have been exciting developments in the recent period regarding the global minimum tax. Based on the latest political agreements, American corporate groups may be exempted from the global minimum tax or from the application of the rules. This news is undoubtedly beneficial for American multinationals, but it also raises many questions regarding the further operation of the still-new system.

The issue of the global minimum tax has become a divisive and politically sensitive issue for some time now. In the United States, warnings have been issued about the loss of competitiveness of American companies in cases where other states tax American companies based on the rules of the global minimum tax.

After his second inauguration, Donald Trump issued two presidential decrees, in which he declared the US’s withdrawal from the OECD agreement on a global minimum tax and, on the other hand, threatened countermeasures against countries that introduce a global minimum tax. Subsequently, the US side increasingly demanded that the taxation of US corporate groups remain within the framework of US rules and that they not be subject to the current rules of the global minimum tax. In order to enforce this, the budget bill submitted to Congress also included a proposal to introduce a punitive tax that would have extremely increased US tax burdens on countries that introduced the global minimum tax, such as withholding taxes, even overriding existing tax treaties.

At the end of June, US Treasury Secretary Scott Bessent announced that an agreement had been reached at the G7 level that US corporate groups would not be affected by the global minimum tax in the future. In return, the measure that would have primarily targeted countries that imposed the global minimum tax on US corporate groups was removed from the US budget bill. Subsequently, the G7 and the OECD issued statements in a supportive tone, and the US legislature also passed the budget bill without the planned punitive measure, which the President signed on July 4.

The transformation of such a complex system as the global minimum tax raises many questions. For example, it is not yet known how the exclusion of US corporate groups from the system will be technically implemented. The most likely solution seems to be a permanent “safe harbor”, which could be applicable in EU member states, without amending the relevant EU directive,

– said Ferenc Póczak, Partner in the Tax Department of Deloitte Hungary.