Report: U.S. Companies Consistently Exceed the Global Minimum Tax, Reinforcing the Case for a Parallel System

A new report by PwC, prepared for the Alliance for Competitive Taxation, shows that American multinational companies already pay well above the 15 percent global minimum tax threshold. Between 2012 and 2024, the average foreign tax rate on U.S. firms’ overseas income exceeded 15 percent every single year. When combined with the residual U.S. taxes on that income, the effective rate climbed above 25 percent as recently as 2021.

The findings come as the OECD and G20 continue to negotiate the details of the global minimum tax, known as Pillar Two. This data justifies the U.S. exemption recently endorsed by the G7, showing that America’s system already achieves the same objectives through a parallel approach. Enshrining that recognition in OECD rules is essential to prevent double taxation, reduce unnecessary compliance burdens, and support the OECD’s effort to build a fair, workable global tax system.