Base erosion and profit shifting

Uzbekistan joins the Inclusive Framework on BEPS and participates in the agreement to address the tax challenges arising from the digitalisation of the economy


09/06/2023 – Uzbekistan joins international efforts against tax evasion and avoidance by joining the OECD/G20 Inclusive Framework on BEPS.


Through its membership, Uzbekistan has also committed to addressing the tax challenges arising from the digitalisation of the economy by joining the two-pillar plan to reform the international taxation rules and ensure that multinational enterprises pay a fair share of tax wherever they operate.


Collaborating on an equal footing with all other members of the Inclusive Framework, Uzbekistan will participate in the implementation of the BEPS package of 15 measures to tackle tax avoidance, improve the coherence of international tax rules and ensure a more transparent tax environment.


Under Pillar One, which is designed to ensure a fairer distribution of taxing rights among jurisdictions over the largest and most profitable multinational enterprises (MNEs), it is now expected to allocate taxing rights on about USD 200 billion in profits to market jurisdictions annually. This is expected to lead to annual global tax revenue gains of between USD 13-36 billion, based on 2021 data. Developing country revenue gains are expected to be greater than those in more advanced economies, as a proportion of existing revenues.


Pillar Two introduces a global minimum corporate tax rate set at 15%. The new minimum tax rate will apply to companies with revenue above EUR 750 million and is estimated to result in annual global revenue gains of around USD 220 billion, or 9% of global corporate income tax revenues. Further benefits will also arise from the stabilisation of the international tax system and the increased tax certainty for taxpayers and tax administrations.


Countries are aiming to agree on a multilateral convention by mid-2023. The convention will be the vehicle for implementation of the newly agreed taxing right under Pillar One, as well as for the standstill and removal provisions in relation to all existing Digital Service Taxes and other similar relevant unilateral measures. This will bring more certainty and help ease trade tensions. The OECD has developed model rules and commentary for bringing Pillar Two into domestic legislation, and has already been introduced in a number of jurisdictions.


The full list of members of the Inclusive Framework on BEPS can be found at:


Further information on the continuing international tax reform negotiations is available at:


Media enquiries should be directed to Manal Corwin (+33 1 4524 9108), Director of the OECD Centre for Tax Policy and Administration (CTPA), Ben Dickinson (+33 1 4524 1529), Head of Global Relations and Development Division (CTPA) or the CTPA Communications Office.


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