Treasury reached agreement with the more-than-145-country OECD/G20 Inclusive Framework to exempt U.S.-headquartered companies from OECD Pillar Two and have them subject only to U.S. global minimum taxes.

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Public documentation (Inclusive Framework agreement text, joint statement, or official communications) exists showing a side-by-side agreement with the Inclusive Framework/145+ countries that exempts U.S.-headquartered companies from Pillar Two and specifies they remain subject only to U.S. global minimum taxes.

Source summary

The U.S. Treasury, represented by Secretary Scott Bessent, announced that it reached an agreement with over 145 countries in the OECD/G20 Inclusive Framework to exempt U.S.-headquartered companies from the OECD Pillar Two rules. The Treasury says the deal keeps U.S. multinationals subject only to U.S. global minimum taxes, preserves the U.S. R&D tax credit and other congressional incentives, and affirms U.S. tax sovereignty. Treasury said it will continue engaging with foreign governments to implement the agreement and pursue further discussions on digital taxation.

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Latest fact check

Evidence from the OECD and independent reporting indicates that more than 145 countries in the OECD/G20 Inclusive Framework agreed to a “side‑by‑side” package under Pillar Two that grants special safe harbours to multinational groups headquartered in jurisdictions (including the United States) with an “eligible” domestic minimum tax regime. The OECD’s January 5, 2026 administrative guidance explicitly describes a Side‑by‑Side System in which those groups are exempt from the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) in other jurisdictions, while remaining subject to their home country’s global minimum tax; Qualified Domestic Minimum Top‑up Taxes (QDMTTs) in market jurisdictions are left unaffected. An OECD press release the same day confirms that 147 Inclusive Framework members agreed this package to accommodate such side‑by‑side regimes, and Reuters reports that more than 145 countries approved updates addressing U.S. concerns via a side‑by‑side framework. Although U.S.-parented groups can still face QDMTTs abroad, the core claim—that Treasury secured agreement within the 145‑plus country Inclusive Framework for U.S.-headquartered companies to be governed by U.S. global minimum taxes instead of Pillar Two’s IIR and UTPR—is supported by these primary and independent sources.

Verdict: True, because OECD documentation and major independent reporting show that the Inclusive Framework adopted a side‑by‑side arrangement under which U.S.-headquartered multinationals are carved out of Pillar Two’s top‑up rules and instead remain under U.S. global minimum tax rules, consistent with the statement’s substance.

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Update · Jan 06, 2026, 12:29 AMTrue
Evidence from the OECD and independent reporting indicates that more than 145 countries in the OECD/G20 Inclusive Framework agreed to a “side‑by‑side” package under Pillar Two that grants special safe harbours to multinational groups headquartered in jurisdictions (including the United States) with an “eligible” domestic minimum tax regime. The OECD’s January 5, 2026 administrative guidance explicitly describes a Side‑by‑Side System in which those groups are exempt from the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) in other jurisdictions, while remaining subject to their home country’s global minimum tax; Qualified Domestic Minimum Top‑up Taxes (QDMTTs) in market jurisdictions are left unaffected. An OECD press release the same day confirms that 147 Inclusive Framework members agreed this package to accommodate such side‑by‑side regimes, and Reuters reports that more than 145 countries approved updates addressing U.S. concerns via a side‑by‑side framework. Although U.S.-parented groups can still face QDMTTs abroad, the core claim—that Treasury secured agreement within the 145‑plus country Inclusive Framework for U.S.-headquartered companies to be governed by U.S. global minimum taxes instead of Pillar Two’s IIR and UTPR—is supported by these primary and independent sources. Verdict: True, because OECD documentation and major independent reporting show that the Inclusive Framework adopted a side‑by‑side arrangement under which U.S.-headquartered multinationals are carved out of Pillar Two’s top‑up rules and instead remain under U.S. global minimum tax rules, consistent with the statement’s substance.
Original article · Jan 05, 2026
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