What the OECD Released on 21 July 2026
On 21 July 2026 the OECD published the eighth edition of its flagship Corporate Tax Statistics database, together with a headline finding that the accompanying press release framed bluntly: corporate tax revenues remain elevated while tax rates stabilise. Buried in the data — and in a companion economic-impact analysis published in the same cycle — is the single most consequential number in international tax this year: the first empirical estimate of what the 15% global minimum tax actually raises.
For three years, every figure attached to Pillar Two has been a projection. The OECD modelled it, think tanks re-modelled it, and finance ministries built budgets around estimates. The 2026 release is different because it draws on observed 2024 outcomes — the first fiscal year for which the rules were live in early-adopter jurisdictions — rather than a forward-looking model. That makes it the first time the world can check the marketing against the receipts.
The Headline: €79–109bn in Year One
According to the OECD's new analysis on the economic impacts of the Global Minimum Tax, the 15% floor generated between €79 billion and €109 billion (roughly US$90–124 billion) in additional corporate tax revenue in its first year of implementation. That is equivalent to 2.4% to 3.4% of global corporate income tax receipts — a meaningful uplift for a single reform, and, as Bloomberg Tax reported, the first number grounded in real filings rather than a model.
Crucially, this is additional revenue attributable to the minimum tax — the top-up collected because in-scope multinationals' jurisdictional effective tax rates were pushed up to the 15% floor, plus the behavioural response of countries raising domestic rates to capture the revenue themselves rather than cede it abroad. The OECD's methodology, as summarised by Reuters, relies on observed company behaviour following implementation, not the modelling assumptions used in the OECD's earlier estimates.
| Metric | Value | Basis |
|---|---|---|
| Year-one revenue (EUR) | €79bn – €109bn | Observed 2024 data |
| Year-one revenue (USD) | ~$90bn – $124bn | Observed 2024 data |
| Share of global corporate income tax | 2.4% – 3.4% | Observed 2024 data |
| Earlier OECD long-run projection | $155bn – $192bn / year | Pre-implementation model |
| Year-one vs. earlier projection | ~58% – 65% of range | Comparison |
Why It Came In Below Forecast
The €79–109bn haul is real money, but it sits below the OECD's own pre-implementation projection, which had put eventual annual returns from the reform at roughly US$155–192 billion. On the numbers, year one delivered somewhere around 58% to 65% of that earlier range. That gap is the story advisers and finance ministries are dissecting, and there are several non-alarming reasons for it.
First, this is a first-year, phased snapshot. In 2024 the Income Inclusion Rule was live in a cohort of early adopters (the EU member states, the UK, and others), but the Undertaxed Profits Rule backstop and many jurisdictions' domestic top-up taxes were only beginning to bite. The OECD's earlier figure was a long-run, fully-implemented estimate; comparing a partial first year to a steady-state projection overstates the "shortfall."
Second, behaviour has already shifted. A central design feature of Pillar Two is that it encourages low-tax jurisdictions to raise their own rates (via a Qualified Domestic Minimum Top-up Tax) so they collect the top-up instead of exporting it. Where that has happened, revenue shows up as ordinary domestic corporate tax, not as GloBE top-up — so some of the "missing" money is simply sitting in a different line of the accounts. The OECD's finding that statutory rates have stopped falling (below) is consistent with exactly this dynamic.
Third, the US carve-out matters. The January 2026 Side-by-Side agreement, which treats the US minimum-tax regime as running alongside GloBE rather than being topped up by it, removes a large slice of profit from the international top-up base. Revenue that models once attributed to Pillar Two now flows through the US system instead.
No Evidence of Harm to Jobs or Investment
The second major finding is arguably more politically important than the revenue number. The OECD reports that companies covered by the rules experienced higher effective tax rates — the intended effect — while it found limited to no evidence of negative effects on investment or employment. This directly rebuts the most common objection to a global minimum tax: that raising the floor would chase capital and jobs out of higher-tax locations or chill cross-border investment.
Because the assessment is built on observed post-implementation data rather than a model, this is a stronger claim than the OECD could make before. It does not settle the debate — one year is a short window, and second-order effects can take time to appear — but it removes the "it will destroy investment" argument's strongest footing, at least for the initial period. For multinationals, the practical message is that the compliance burden is real, but the doomsday macro scenario has not materialised in the first year of data.
Corporate Tax Rates Have Stopped Falling
Corporate Tax Statistics 2026 also confirms a structural turning point. The average statutory corporate income tax rate across covered jurisdictions was 21.2% in 2026 — essentially unchanged from 21.2% in 2020. After two decades of a near-continuous global "race to the bottom," rates have flattened. The OECD explicitly links this stabilisation to the arrival of the 15% floor, which reduces the incentive for any single country to keep cutting.
Forward-looking effective rates tell a similar story. Per the OECD's corporate effective tax rates chapter, the average composite effective average tax rate (EATR) sits at about 20.5%, with asset-specific EATRs of roughly 19.3% for buildings and 19.7% for other tangible assets.
| Rate measure | 2026 average | Trend |
|---|---|---|
| Statutory corporate income tax rate | 21.2% | Flat vs. 21.2% in 2020 |
| Composite effective average tax rate (EATR) | 20.5% | Stabilising |
| EATR — buildings | 19.3% | — |
| EATR — other tangible assets | 19.7% | — |
What the Data Shows on Withholding Tax
For anyone modelling cross-border payments, the most directly useful chapter is the OECD's withholding tax rates and tax treaties dataset. Across 146 jurisdictions, the 2026 edition reports average statutory (non-treaty) withholding tax rates of:
| Payment type | Average statutory WHT rate (2026) |
|---|---|
| Dividends | 12.2% |
| Interest | 12.8% |
| Royalties | 14.5% |
These are statutory domestic rates — the rate that applies absent a treaty. In practice, a tax treaty between the payer's and recipient's countries usually reduces them substantially, often to 0–10% for dividends, interest, or royalties, provided the recipient meets beneficial-ownership and documentation requirements. The gap between the ~12–15% statutory averages and treaty-reduced rates is precisely why treaty analysis is worth doing on every cross-border flow. For a country-by-country reference of headline rates, see our Withholding Tax Rates by Country guide, and for the mechanics of accessing lower treaty rates, our How to Claim Tax Treaty Benefits guide.
What the CbCR Data Reveals About MNEs
The 2026 edition expands its anonymised and aggregated country-by-country reporting dataset to cover the activities of almost 9,400 multinational enterprises headquartered in more than 60 jurisdictions. This is the closest thing the world has to an X-ray of where large multinationals book profit, pay tax, and employ people.
One number stands out for tax administrators: large MNEs contributed an average of 44.5% of total corporate tax revenues in 2023, up from 42.8% in 2017 across the 60 reporting jurisdictions. In other words, the biggest groups are shouldering a growing share of the corporate tax base — a trend that predates Pillar Two but which the minimum tax is designed to reinforce by ensuring that share is taxed at no less than 15% wherever profit is booked.
The CbCR data continues to show a persistent misalignment between where profits are reported and where real activity (employees, tangible assets) sits — the very base-erosion pattern the BEPS project set out to address. The 2026 figures suggest the gap is narrowing at the margin as the minimum tax takes hold, but it has not closed. For the underlying framework, see our BEPS Pillar Two explained guide.
What This Means for Tax Teams
The 2026 data shifts Pillar Two from a compliance project defended on principle to one with an empirical track record. For in-house tax and finance functions, several practical implications follow.
- The floor is here to stay. A reform generating tens of billions in year one, with rates stabilising and no measurable investment harm, is politically durable. Planning that assumes Pillar Two might be rolled back is planning on a weak foundation.
- Domestic rate rises are the quiet trend. Because jurisdictions increasingly prefer to collect the top-up themselves via a QDMTT, expect more low-tax locations to raise headline rates toward 15%. Model your effective rates jurisdiction by jurisdiction rather than relying on historic low-tax assumptions.
- Data quality is the differentiator. The revenue "shortfall" partly reflects safe harbours and the US carve-out. Whether your group captures those benefits depends on the quality of its CbCR and GloBE data — the same data the OECD is now aggregating to measure the policy.
- Withholding tax still bites. With statutory WHT averages of 12–15%, treaty positioning on dividends, interest and royalties remains one of the highest-return areas of cross-border planning, entirely separate from the minimum-tax layer.
For related reading, see our guides on the Pillar Two Side-by-Side Package 2026, the UK Finance Bill 2026-27 implementation, and the GloBE Information Return filing deadline.
Frequently Asked Questions
How much did the global minimum tax raise in its first year?
The OECD's 2026 economic-impact analysis estimates the 15% global minimum tax generated between €79 billion and €109 billion (roughly US$90–124 billion) in additional corporate tax revenue in its first year — equivalent to 2.4% to 3.4% of global corporate income tax receipts. This is the first estimate based on observed post-implementation data rather than a forward-looking model.
Why is that below the OECD's earlier projection?
The OECD had previously projected long-run annual revenue of roughly US$155–192 billion, so year one delivered about 58–65% of that range. The gap reflects phased implementation (the Undertaxed Profits Rule and many domestic top-up taxes were only beginning in 2024), jurisdictions raising their own domestic rates so the revenue appears as ordinary corporate tax rather than GloBE top-up, and the US Side-by-Side carve-out removing part of the international top-up base.
Did the global minimum tax hurt investment or jobs?
Not on the first year of data. The OECD found that covered companies faced higher effective tax rates, as intended, but reported limited to no evidence of negative effects on investment or employment. Because the finding is based on observed 2024 outcomes rather than a model, it is a stronger rebuttal of the "it will chase away capital" argument than the OECD could previously offer, though one year is a short observation window.
What are the average withholding tax rates in the 2026 data?
Across 146 jurisdictions, the OECD reports average statutory (non-treaty) withholding tax rates of 12.2% on dividends, 12.8% on interest and 14.5% on royalties. Tax treaties typically reduce these substantially, which is why treaty analysis remains central to cross-border payment planning.
Have corporate tax rates stopped falling?
Yes, according to the OECD. The average statutory corporate income tax rate was 21.2% in 2026, essentially unchanged from 21.2% in 2020, arresting the roughly two-decade downward trend. The OECD attributes the stabilisation in part to the 15% global minimum tax reducing the incentive for countries to keep cutting rates.
For a foundational explanation of how the 15% global minimum tax works, start with our BEPS Pillar Two explained guide.