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Minister Gualtieri’s speech at the “OECD/G20 Inclusive Framework on BEPS”


Speech by Minister of the Economy and Finance Roberto Gualtieri at the
“11th meeting of the OECD/G20 Inclusive Framework on BEPS”


I think that this conversation is showing that there is an uncontroversial premise on which the political response to the challenges raised by the digitalization and globalization of the economy is based, and that is that these are global issues that require a global answer.

Let me start by commending the work done by the Inclusive Framework with the approval of the two Reports on the Blueprints for Pillar 1 and Pillar 2, recognized by the G20 to constitute a solid basis for further progress towards the consensus-based international solution that we must agree by mid-2021, the deadline set by the G20 Leaders in November last year.

I think that there is also a positive and broad agreement on this conversation that the review of the existing international tax rules is really urgent, and it’s positive that we all share this sense of urgency, of which the Italian Presidency is fully aware.

On Pillar 1, I fully agree with what has been said, in particular there are two points to be made, one related to fairness and the other to stability.

First, we need to restore the fairness of the international tax system. Traditional businesses pay taxes on their profits in the markets where they operate while digital companies do not as they can conduct economic activity remotely without taxable presence. The Covid-19 outbreak has exacerbated this distortion. The crisis has provoked major disruptions to the global supply chains and digital businesses have flourished, increasing significantly their global profits.

The new rules that the Inclusive Framework is discussing under Pillar 1 would result in a fairer allocation of profits among jurisdictions, ensuring that taxation takes place where economic value is created regardless of the business models.

Second, reforming the existing rules is critical to guarantee a more stable tax environment, with greater tax certainty for multinational enterprises. Tax certainty is crucial to support investment decisions by multinational enterprises and this is extremely important in the recovery phase after the pandemic.

It must be clear to everyone that the alternative to an international agreement is not the status quo. In the absence of an international agreement, countries will follow diversified strategies and adopt uncoordinated responses, with the result of fragmentation of the tax measures, risks of double taxation and increase of tax disputes.

On that account I should add that, as you know, in Italy we have a digital services tax in force but our DST includes a “sunset clause” that provides that the tax will be repealed as soon as an internationally agreed solution is implemented.

A coordinated solution is necessary to bring stability to the international tax system, prevent further uncoordinated measures and reduce trade tensions triggered by unilateral initiatives.

Along with the revision of the rules on allocation of profits, we need new rules to tackle the remaining BEPS issues due to the persistence of corporate income tax rate differentials, by establishing a global minimum effective taxation.

We strongly support the work on Pillar 2 aimed at establishing new and effective rules that will reduce incentives for multinational enterprises to move profits in low-tax jurisdictions, by levelling the playing field among countries and preventing a “race to the bottom” that, in perspective, may have an unsustainable impact on corporate income tax revenues.

After so many years of work and debates on the appropriate and coordinated tax response to the challenges of the digitalization of the economy, a global agreement is within reach.

The two Blueprints are a strong basis to build upon and I encourage all members of the Inclusive Framework to address and solve the outstanding open technical issues.

In particular, it is essential to complete the work on simplification of the rules to ensure their consistent implementation worldwide, while minimizing the compliance burden for taxpayers and the enforcement costs for tax administrations.

Let me conclude by reiterating the urgency of the global agreement. We should also take into account that the new international tax rules will be an essential component of the reforms that will be enacted for ensuring the sustainability of public finances in the post-pandemic phase.

G20 Presidency

We are aware that there are high expectations on the G20 to agree on the review of international tax rules and to meet this deadline of mid 2021. So of course this is a top priority on our G20 agenda. And for doing so we will engage with all parties involved, including, of course, the new US administration, to help bridging the remaining gaps and build political consensus.

We will also engage very closely with the UK G7 Presidency. With Rishi I have discussed the importance of making progress finding this common solution.

I’m also glad to have the opportunity to share our priorities for the Italian G20 Presidency with all the delegates to the Inclusive Framework, in particular in the area of taxation.

As you know we have identified in our vision 3 pillars - People, Planet Prosperity - being aware that this is a crucial year not only for recovering from the pandemic but also to try to strengthen a transformation of our global economy towards common goals of sustainability, resilience, innovation and inclusion.


  • People: because all policy actions will be centred on people. This means tackling inequalities and promoting equal opportunities.
  • Planet: because we need to restore balance between people and nature. Our global commitments to the Paris Agreement can no longer be postponed.
  • Prosperity: because global growth should be seen as a tool to ensure prosperity. In particular, we should strive to make technological transformation and digitalisation an opportunity for all.

Within this framework, in the Finance Track we will aim to complement the policies aimed at sustaining the recovery with the development of long-term strategies that can promote the transformation towards fairer, greener, more digital and inclusive societies.

The focus will be on six priorities:

  • ensure health as a global common good and strengthen pandemic preparedness;
  • promote an international environment conducive to investment and growth;
  • maintain global financial stability while enhancing financial inclusion in a digital world;
  • support vulnerable economies and strengthen the international financial architecture;
  • protect our planet while improving living conditions for all;
  • make the international tax system more fair and transparent.

In particular, on international taxation - beyond digital taxation - we will work on tax transparency where, despite the substantial progress achieved over the past years, we believe that it is important to tackle new emerging risks originating from technological developments. The OECD is currently developing a reporting framework for automatic exchange of information on crypto-assets and we aim to endorse it at the G20 Finance Ministers meeting in October.

On BEPS (Base Erosion and Profit Shifting), the Italian Presidency is committed to endorse the review of the minimum standards on Country by Country Reporting, Mutual Agreement Procedures, as well as the revised methodology to review the minimum standard on Tax Treaty Abuse.

On tax and development, strengthening Domestic Resource Mobilisation in developing countries through enhancement of their capacity in tax policy and tax administration remains a high priority. While it is crucial to exploit synergies among the different initiatives already launched in this area, we intend to mandate the OECD to prepare a report to the G20 on the benefits that developing countries derive from their participation to the Inclusive Framework.

We intend to launch a discussion on the role of tax policy to support the transition to a low-carbon global economy, promote green technologies and investments, and encourage the use of more efficient and less polluting energy sources.

The 2021 High level Tax Symposium that will be held back to back to the July meeting of the Finance Ministers, hopefully in person in Venice, will deal with environmental taxation and the outcome of this discussion will feed in a broader high-level event on the role of economic, fiscal and financial policies in shaping a greener recovery.

Finally, we will mandate the OECD to produce for the April meeting an update of the report delivered last year on “Tax Policy and COVID-19” and to present in October a new report on “Tax policy after Covid-19”.

We have indeed an ambitious program and we count on the support of all colleagues of the G20 countries and of course of the excellent work of Oecd.

Final remarks

I want to say that we are going through an unprecedented crisis, which is unique for its nature and its persistency. But we have to be aware that we have also big opportunities and we must be prepared to reap these opportunities.

And, indeed, we do have the opportunity to find a consensus and an agreement on digital taxation, on Pillar 1, on Pillar 2. This has been a very positive debate and I’m confident that we can do this; and we are of course very determined to reach together this goal with the participation of everyone, thank you.


Video: link to external website
Minister Gualtieri’s speech at the “OECD/G20 Inclusive Framework on BEPS”