KO · 10-Q · 2026Q4 · Full report

OECD Global Minimum Tax

COCA COLA CO · 2026-10-28 · Importance 34 · Surprise 42

The OECD Pillar Two model rules establish a 15% global per-country minimum tax, with numerous countries implementing provisions effective in 2024 or 2025. In January 2026, the OECD issued guidance for a side-by-side framework that largely exempts U.S.-headquartered companies from Pillar Two, following a June 2025 G7 statement on a potential approach. Further revisions and country-level implementation remain expected, and Coca-Cola says it will monitor the potential impact in the countries where it operates. Based on current tax laws, including global minimum tax regulations, the company expects a 2026 effective tax rate of approximately 19.7%, before significant operating and nonoperating items and excluding the potential impact of the IRS litigation if the company does not prevail.

Key facts

• In January 2026, the OECD issued Pillar Two administrative guidance introducing a side-by-side framework that largely exempts U.S.-headquartered companies; Coca-Cola will monitor developments for potential impact in countries where it operates. source
• The OECD's Pillar One proposal would reallocate a portion of profits earned by multinational businesses with annual global revenue exceeding €20 billion and profit margins over 10% to applicable market jurisdictions; the implementation timetable remains uncertain. source
• The OECD issued Pillar Two model rules in December 2021 to establish a global per-country minimum tax of 15%; EU rules were initially to take effect for fiscal years starting on or after December 31, 2023. source