Tax Cooperation Policy Brief No. 41, 27 February 2026
OECD Two Pillar Solution: Designed to Prevent the Offshoring of High Tech Production to the Global South
By Abdul Muheet Chowdhary
The Organisation for Economic Co-operation and Development (OECD) Two Pillar solution is a tool of the developed countries designed to: a) prevent Multinational Enterprises (MNEs) in frontier technologies like clean energy, computing, semiconductors, etc. from offshoring production to developing countries, and b) minimize Global North MNEs’ taxable profits in developing countries. The recent exemption of the United States’ MNEs from certain aspects of the OECD Global Minimum Tax further strengthens these objectives. South Centre Member States and other developing countries should resist pressures to adopt the Two Pillar solution and make informed, evidence-based decisions, while considering the benefits of other simpler and more beneficial alternatives.