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G7 statement

On 28 June 2025, the G7 issued a statement expressing a ‘shared understanding’ that the domestic and foreign profits of US-parented multinational groups would be excluded from the scope of Pillar Two, the OECD-G20 global minimum corporate tax framework. Instead, the G7 signalled readiness to work on a ‘side-by-side’ approach in which the US GILTI regime, its current minimum tax on foreign earnings of US parented groups – would co-exist with Pillar Two. The statement allowed for the withdrawal of proposed US retaliatory measures (‘section 899’) that had been included in the One Big Beautiful Bill Act (OBBBA).

Reminder: Pillar Two applies a 15 % global minimum effective tax rate using a hierarchical rule order to ensure large multinational enterprises are taxed appropriately in each jurisdiction:

• 1. The Qualified Domestic Minimum Top-Up Tax (QDMTT) – Gives the local jurisdiction first claim to top up low-taxed domestic profits.
• 2. The Income Inclusion Rule (IIR) – The ultimate parent’s jurisdiction imposes a top-up tax on the local parent entity to make up for any remaining low-taxed profits of foreign entities.
• 3. The Undertaxed Profits Rule (UTPR) – If the IIR is not applied by the ultimate parent’s jurisdiction, the UTPR steps in as a backstop, with lower-tier jurisdictions imposing top-up taxes on local entities to make up for any remaining low-taxed profits in the parent jurisdiction or any other third jurisdiction.

Council Directive (EU) 2022/2523 introduced Pillar Two’s minimum tax rules in the EU.

Given the broad nature of the G7 statement, which speaks of ‘accepted principles’, it is difficult to draw definitive conclusions at this stage. Based on its wording, a side-by-side approach – if endorsed by the OECD Inclusive Framework – could imply that non-US jurisdictions would not apply the UTPR to local entities of US-parented groups in respect of low-taxed profits arising in the US or in another jurisdiction that does not apply the QDMTT or the IIR. However, the statement does not explicitly clarify the specific terms of the exemption. For instance, it does not address how US intermediary parent entities within non-US multinational groups would be treated for minimum tax purposes, the potential creditability of the GILTI tax in relation to a jurisdiction’s QDMTT, or how the side-by-side approach would be defined in legislation.

NCTI and Pillar Two

As Pillar Two and the US’ GILTI (now called ‘NCTI’ under the OBBBA) operate on different principles and design features, it is difficult to assess to what extent the side-by-side approach could raise concerns about a level playing field or lead to base erosion and profit shifting among the multinational companies subject to each regime. Potential competitive disadvantages arise not only from differences in direct tax liabilities but also from the variations in the administrative and legal complexity of the respective regimes.

The OBBBA, signed into law in July 2025, introduced several adjustments allowing NCTI to more accurately reflect the real outcomes of Pillar Two. It increased the effective tax rate to 14 % (up from 13.125 %) and removed the carve-out for the Qualified Business Asset Investment (QBAI), thereby broadening the taxable base.

However, a key difference between the two systems remains: the ‘blending’ of income. Pillar Two requires corporate groups to meet a minimum level of tax in each jurisdiction where they operate (‘jurisdictional blending’), while the US’ NCTI allows income and foreign taxes to be blended across all foreign countries (‘global blending’). This way, low-taxed income can be offset with high-taxed income elsewhere and profits in some jurisdictions can be reduced by losses in others.

Table 1 – Key comparisons between OECD G20 Pillar Two and US NCTI

 OECD-G20 – Pillar TwoUS – NCTITax rate15 %14 %Tax baseBased on accounting incomeBased on US taxable incomeBlendingJurisdictional blendingGlobal blendingCarve-outsBased on payroll and tangible assets (SBIE)Payroll or tangible assets do not qualify for a carve-out

Note: The effective 14 % floor of NCTI results from the interaction of the 21 % US statutory corporate tax rate, the 60% inclusion of NCTI taxable income and the 90 % foreign tax credit limitation ((21 % * 60 %)/90 % = 14 %).

Additionally, the OBBA introduced broader corporate tax changes, such as permanent expensing for domestic R&D investments and a higher interest deductibility cap, to enhance US competitiveness.

Pillar One

The G7’s statement noted that the delivery of the side-by-side system ‘will facilitate further progress to stabilize the international tax system, including a constructive dialogue on the taxation of the digital economy’, referencing the negotiations on Pillar One. During the September 2025 plenary session, in response to questions from Members of the European Parliament on Pillar One and the prospects for a European digital services tax (DST), the European Commission acknowledged that Pillar One discussions were ‘on hold’ but could resume once a Pillar Two solution is reached. To give the OECD-led process space and time to deliver, the Commission stated that it does not intend to table a new proposal for a DST at this stage.

Several countries have already implemented or announced digital services taxes (DSTs), with revenues steadily increasing over time, showcasing the continuous growth of the digital economy. In 2023, Spain, Italy and France collectively generated €1.4 billion from their DSTs. However, estimating the revenue potential of an EU-wide DST would heavily depend on key design parameters, such as the definition of in-scope activities (the types of digital services or business activities that would fall under the tax), the applicable tax rate, and the revenue thresholds.

Table 2 – Revenue of DSTs, € million, 2019-2023

Revenue (€ million)20192020202120222023Spain  €166€295€323France€277€375€474€621€668Italy €233€303€394€434

Data source: Data on Taxation Trends – European Commission. All three countries apply a 3 % DST on turnover from online advertising, user data sales and digital platforms, with a €750 million global revenue threshold and varying domestic thresholds: €3 million (Spain), €25 million (France), and €5.5 million (Italy; lowered to €0 in 2025).

Read this ‘at a glance’ note on ‘Side by side? The future of Pillar Two minimum corporate tax rules‘ in the Think Tank pages of the European Parliament.

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Committees

Source : © European Union, 2025 - EP

Activists say the lack of a concrete 2035 UN climate pledge by a deeply divided EU is an embarrassment

Julia Francisco Martínez stands at the graveside of her husband Juan, a Honduran Indigenous defender who was found murdered in 2015. Credit: Giles Clarke / Global Witness

By Umar Manzoor Shah
LONDON & SRINAGAR, Sep 19 2025 (IPS)

At least 146 land and environmental defenders were murdered or forcibly disappeared in 2024 for standing up against powerful state and corporate interests, according to a new report released by Global Witness.

The findings, published under the title Roots of Resistance, expose a persistent global crisis that has claimed 2,253 lives since 2012, and show that violence against those protecting land, forests, and communities continues with little sign of justice.

Although the 2024 figure is lower than the 196 killings recorded in 2023, Global Witness cautions that this does not represent progress. Instead, it reflects chronic underreporting, difficulties in verifying cases in conflict zones, and a climate of fear that silences victims’ families and communities.

Latin America: The Epicenter of Attacks

The report shows that 82 percent of documented killings took place in Latin America. Colombia once again topped the global list, with 48 killings accounting for nearly a third of all cases worldwide. The victims were mostly community leaders, Indigenous defenders, and small-scale farmers confronting mining, agribusiness, and organized crime.

Despite government pledges of reform, Colombia’s weak state presence in former conflict zones has allowed armed groups and criminal networks to dominate. This has created a deadly environment for activists who resist environmental destruction.

Mexico followed with 19 cases, including 18 killings and one disappearance. It marked the second most lethal year for Mexican defenders in the past decade. Brazil recorded 12 killings, half of them small-scale farmers.

The most alarming rise was seen in Guatemala, where killings spiked from four in 2023 to 20 in 2024, giving the country the highest per capita murder rate for defenders worldwide. This escalation took place despite the election of President Bernardo Arévalo, who had promised to curb corruption and inequality.

“Eighty-two percent of recorded attacks in 2024 were in Latin America, where we have consistently seen the highest proportion of cases for over a decade,” said Laura Furones, Senior Advisor at Global Witness and one of the report’s authors, in an interview with Inter Press Service. “Killings were concentrated in four countries, which together accounted for around 70 percent of the murders: Colombia, Guatemala, Mexico, and Brazil.”

According to Furones, Latin America’s rich natural resources, combined with strong civil society movements and widespread impunity, make it both a hotspot for extraction-related conflicts and for reporting of violence. “High levels of impunity mean there is little disincentive for violence to stop,” she said.

Who Are the Victims?

The report found clear patterns in who is most targeted. In 2024, 45 Indigenous defenders and 45 small-scale farmers were killed or disappeared. Together, they made up nearly two-thirds of all cases.

These killings are closely linked to profit-driven industries. Mining was identified as the deadliest sector, connected to 29 killings. Logging was tied to eight deaths, agribusiness to four. Organized crime was implicated in nearly a third of all attacks, often working with or tolerated by state forces.

State actors themselves, including police and military, were linked to 17 killings. In Colombia, only 5.2 percent of murders of social leaders since 2002 have been resolved in court, leaving the intellectual authors of the crimes almost untouched.
“Impunity fuels this cycle of violence,” the report notes. “Without justice, perpetrators feel emboldened to repeat attacks.”

Documenting Violence in Hostile Environments

Global Witness compiles its data through a systematic process of reviewing public information, analyzing datasets, and collaborating with local and regional organizations in more than 20 countries. Each case must be verified by credible sources with detailed information about the victim and the link to land or environmental defense.

Still, Furones acknowledged that many attacks go undocumented, particularly in authoritarian states, regions with limited civil society, or conflict zones. “These figures are likely underestimates,” she said.

Personal Stories Behind the Numbers

Beyond the statistics, the report highlights individual defenders whose struggles illustrate the human cost of the crisis.

In Nigeria, the Ekuri community has spent decades protecting one of West Africa’s last tropical rainforests. Activists like Louis Friday, Martins Egot, and Odey Oyama face threats from armed loggers and corrupt officials. Oyama was arrested in January 2025 by a masked police squad and charged with “promoting inter-communal war,” a crime that carries a life sentence. He says the charges are retaliation for his conservation work.

In Chile, 72-year-old Mapuche leader Julia Chufil disappeared in November 2024 while fighting to reclaim ancestral land from forestry companies. She had faced harassment and bribery offers for years. Her family, leading the search for her, say authorities have treated them as suspects rather than victims.

In Colombia, campesino leader Jani Silva has been under state protection for over a decade due to death threats tied to her defense of the Perla Amazónica Peasant Reserve. While protection measures have kept her alive, Silva describes them as isolating and burdensome, underscoring the inadequacy of current mechanisms.

Expanding Tactics of Repression

The report stresses that lethal attacks represent only the most visible form of violence. Defenders face a spectrum of threats including harassment, sexual violence, smear campaigns, and criminalization.

“Of particular concern is the rising trend of criminalization, as restrictive laws are increasingly enacted worldwide to make peaceful protest a crime,” Furones said.

She added that toxic anti-defender narratives, combined with Strategic Lawsuits Against Public Participation (SLAPPs), further erode protections.

Authorities in several countries have adopted laws specifically targeting protestors, intensifying crackdowns on land and climate activists. “States are unwilling to protect those who stand up for rights,” Furones said. “Instead, they use the law as a weapon against them.”

A Global Failure of Protection
The report warns that international agreements designed to safeguard defenders are being weakened. Nearly 1,000 defenders have been killed in Latin America since the adoption of the Escazú Agreement in 2018, which was meant to ensure their protection.

Global Witness calls for urgent action from governments and businesses. States must recognize land rights, strengthen laws against corporate abuse, and build effective protection mechanisms. Companies must respect Free, Prior, and Informed Consent, conduct rigorous human rights due diligence, and adopt zero-tolerance policies for attacks on defenders.

Indigenous Peoples are identified as especially vulnerable, living across 90 countries and managing more than a third of Earth’s protected land. Research shows Indigenous and Afro-descendant communities achieve better conservation outcomes than many official protected zones. Yet they often defend their territories with little state support, while their voices are excluded from decision-making.

“Particular protection of Indigenous Peoples requires breaking the cycle of violence,” Furones said. “This means respecting their right to self-determination and ending impunity.”

She cited the recent sentencing of illegal loggers in Peru for the murder of four Indigenous Saweto leaders as a rare but important example of accountability. “It shows the judiciary can play a role, even if justice comes only after a long and painful wait.”

Protection Mechanisms: Lifelines With Limits

State protection measures for defenders vary widely, from providing bulletproof vests and security escorts to emergency relocations. However, most programs are designed for individuals, not communities, despite the collective nature of defenders’ work.

As the case of Jani Silva shows, these measures can protect lives but also isolate defenders from their communities and impose psychological costs. Global Witness calls for expanding and improving protection systems to meet collective needs.

The Road Ahead

The report concludes that defenders remain at the frontline of protecting ecosystems and confronting the climate crisis, yet are increasingly under siege. Without stronger protections and accountability, the risks they face will persist.

Furones stressed that breaking the cycle of violence requires political will, robust legal systems, and corporate responsibility. “Study after study shows Indigenous Peoples and Afro-descendant communities are the best guardians of forests and natural resources,” she said. “Protecting them is not just about human rights; it is also about protecting the planet.”

Furthermore, the Roots of Resistance report  has laid stress on the fact that  while governments and corporations profit from resource extraction, those who safeguard the environment pay with their lives. The global community now faces a choice and that is to strengthen protections and enforce accountability, or allow the cycle of violence to continue unchecked.

IPS UN Bureau Report

 

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