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Title page 1

Contents 5

Foreword 4

Reader's guide 8

Abbreviations, acronyms and jurisdiction names 10

Executive summary 13

1. Corporate tax revenues 15

Introduction 15

Data characteristics 15

Corporate income tax revenues in 2023 16

Corporate income tax revenues trends 20

Notes 22

2. Statutory corporate income tax rates 23

Introduction 23

Data characteristics 23

Statutory corporate income tax rates in 2026 24

Corporate income tax rate trends 26

References 28

Notes 28

3. Withholding tax rates and tax treaties 29

Introduction 29

Data characteristics 30

Withholding tax rates in 2026 30

References 37

Note 37

4. Corporate effective tax rates 38

Introduction 39

Data characteristics 39

Forward-looking corporate effective tax rates in 2025 39

Corporate effective tax rate trends 46

Note 50

5. Tax incentives for research and development 51

Introduction 52

Data characteristics 52

Indicators of R&D tax incentives 2025 (or latest available year) 53

R&D tax incentives trends 60

References 65

Note 65

6. BEPS Actions 66

Introduction 66

Data Characteristics 66

BEPS Actions in 2026 68

References 77

Note 77

7. Country-by-country reporting statistics 78

Introduction 78

Data characteristics 79

CbCR statistics for financial year (FY) 2023 80

Insights on BEPS from CbCR data 90

References 93

Notes 93

Tables 7

Table 7.1. Content of anonymised and aggregated CbCR statistics 80

Table 7.2. Sample composition and average values for key financial variables 82

Figures 6

Figure 1.1. Corporate income tax revenues as a percentage of GDP, 2023 17

Figure 1.2. Corporate income tax revenues as a percentage of total tax revenues, 2023 19

Figure 1.3. Average corporate income tax revenues as a percentage of total tax and as a percentage of GDP 20

Figure 1.4. Average corporate income tax revenues as a percentage of GDP by income group 21

Figure 1.5. Average corporate income tax revenues as a percentage of total tax revenues by income group 21

Figure 2.1. Statutory corporate income tax rates, 2026 25

Figure 2.2. Average statutory corporate income tax rates by region 26

Figure 2.3. Average statutory corporate income tax rates by income group 27

Figure 2.4. Changing distribution of statutory corporate income tax rates 27

Figure 3.1. Statutory withholding tax rates, 2026 32

Figure 3.2. Average withholding tax rates by income groups, 2026 33

Figure 3.3. Average treaty-based withholding tax rates, 2026 34

Figure 3.4. Number of bilateral treaties, 1990-2026 35

Figure 3.5. Average number of bilateral tax treaties by region 35

Figure 3.6. Average number of bilateral tax treaties by income group 36

Figure 4.1. Effective average tax rates, 2025 41

Figure 4.2. Effective marginal tax rate, 2025 43

Figure 4.3. EATR and EMTR: Variation across jurisdictions and assets, 2025 45

Figure 4.4. Changing distribution of corporate effective average tax rates, 2017-2025 46

Figure 4.5. Changing distribution of EATRs by assets, 2017-2025 47

Figure 4.6. Changing distribution of corporate effective marginal tax rates, 2017-2025 48

Figure 4.7. Changing distribution of EMTRs by assets, 2017-2025 49

Figure 5.1. Direct government funding and expenditure-based tax support for business R&D (BERD), 2024 54

Figure 5.2. The effective average tax rate for R&D including expenditure-based tax incentives, 2025 55

Figure 5.3. The cost of capital for R&D, 2025 56

Figure 5.4. Implied marginal tax subsidy rates on business R&D expenditures, 2025 57

Figure 5.5. EATR for internally generated R&D intangibles, 2025 58

Figure 5.6. The cost of capital for internally generated R&D intangibles, 2025 59

Figure 5.7. Changing distribution of the average EATR for R&D, 2019-2025 60

Figure 5.8. Changing distribution of the average cost of R&D capital, 2019-2025 61

Figure 5.9. Evolution of the implied marginal tax subsidy rates R&D, 2000-2025 62

Figure 5.10. EATR and implied tax subsidies for internally generated R&D intangibles, OECD countries, 2000-2025 63

Figure 5.11. Cost of capital of R&D intangibles, OECD countries, 2000-2025 64

Figure 6.1. Rules neutralising hybrid mismatch arrangements, 2026 69

Figure 6.2. Controlled Foreign Company Rules, 2026 70

Figure 6.3. Interest Limitation Rule types, 2026 71

Figure 6.4. Status of intellectual property regimes in place in 2026 73

Figure 6.5. Reduced rates under non-harmful intellectual property regimes, 2026 74

Figure 6.6. Reduced rates under non-harmful (amended) intellectual property regimes, 2026 74

Figure 6.7. Mandatory disclosure rules, 2026 75

Figure 6.8. Number of jurisdictions implementing mandatory CbCR filing 76

Figure 7.1. The evolution of CbCR coverage 81

Figure 7.2. Distribution of MNEs 82

Figure 7.3. MNEs' contribution to total CIT Revenues, 2023 85

Figure 7.4. Jurisdiction groups' shares of foreign MNEs' activities 87

Figure 7.5. Business activities 88

Figure 7.6. Business activities by income group 89

Figure 7.7. Median profits per employee: distribution within income groups 90

Figure 7.8. Median total revenues per employee: Distribution within income groups 91

Figure 7.9. Median related party revenues shares: Distribution within jurisdiction groups 92

Boxes 53

Box 5.1. Three complementary indicators of the generosity of R&D tax support 53

Box 7.1. MNE group structure 79

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