Int'l Tax News

Examines Turkey’s reduction of its digital services tax rate and considers broader implications for digital tax policy and international coordination.

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Reviews international parliamentary efforts to address multinational tax avoidance and the growing use of protectionist tax measures, examining the Inter-Parliamentary Union’s proposed resolution and its potential role alongside existing global tax coordination initiatives led by the OECD/G20 and the U.N. Tax Committee.

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Discusses how AI-driven tax modeling and new legislation are reshaping tax administration and compliance globally.

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This article explores how technological change, regulatory uncertainty, and enforcement pressures are reshaping global transfer pricing risk heading into 2026.

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Examines a new OECD initiative aimed at ensuring mutual agreement procedures remain available for adjustments that are substantively transfer pricing–related but not formally characterized as such.

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Discusses the evolving landscape of tax transparency initiatives heading into 2026, including developments in information exchange standards, reporting obligations, and global forums’ efforts to enhance cross-border cooperation and combat tax evasion

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Reports that the Netherlands plans to introduce legislation implementing the OECD side-by-side package, with stakeholder consultations expected before summer.

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Examines political and policy challenges facing countries engaged in U.N.-led tax negotiations as deadlines approach.

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Discusses proposals from Dutch tax advisers on incorporating the EU’s Unshell initiative into DAC6 reporting obligations through the creation of a new disclosure hallmark.

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Mindy Herzfeld reviews major international tax developments from 2025,  including disruptions to the OECD’s two-pillar project, evolving tariff policy, and legislative, regulatory, and judicial uncertainty, and assesses what these trends suggest for the international tax agenda in 2026.

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Examines the European Commission’s plan to recalibrate its tax agenda in 2026 by prioritizing narrower, targeted initiatives over broad, comprehensive reforms.

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Covers a planned legal challenge to Belgian legislation authorizing tax authorities to use artificial intelligence to mine financial data, focusing on privacy and proportionality concerns.

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Examines unresolved conceptual and practical issues surrounding the treatment of goodwill in transfer pricing analyses and disputes

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The Treasury Department announced an agreement with OECD Inclusive Framework members confirming that certain U.S.-headquartered multinational groups will be exempt from key elements of the Pillar Two global minimum tax regime. The announcement reflects ongoing efforts to align the Pillar Two framework with existing U.S. tax rules, including the treatment of GILTI. Treasury emphasized that the agreement preserves U.S. taxing rights while reducing the risk of double taxation for U.S. multinationals operating abroad. The development has important implications for the future interaction between U.S. international tax law and the OECD’s global minimum tax project.

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This press release announces that the 147 members of the OECD/G20 Inclusive Framework have agreed on key elements of a package advancing the coordinated operation of the global minimum tax, which includes the side-by-side approach reflected in the Tax Notes article

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This article evaluates how the G7’s Pillar Two statement could affect the application of minimum tax rules to U.S.-parented multinational enterprises

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Countries at the United Nations are looking at sweeping changes to transfer pricing rules as they design a tax treaty acceptable to developing economies. But easing access to transfer pricing information could emerge as a more realistic outcome.

Summarizes Ireland’s 2026 budget tax measures, including extensions of credits and reliefs affecting individuals and businesses.

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Examines the European Union’s 2026 tax priorities, highlighting the growing role of soft law, administrative coordination, and simplification efforts alongside carbon border and minimum tax initiatives.

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Businesses will keep a close eye on negotiations at the United Nations over global tax rules, with first drafts and their economic impact studies planned to be released next year.

Five years after the Covid-19 lockdowns, there has been a significant increase in enterprises looking to enable cross-border remote work, partly due to a desire to expand into new markets but predominantly due to increased demand from individuals.

The OECD asked 26 countries to improve their facilitation of tax rulings that help tax authorities in risk assessments and counter base erosion and profit shifting concerns, according to a new report.

The Trump administration threatened retaliation against the European Union in response to efforts to tax American tech companies, singling out prominent companies, including Accenture Plc, Siemens AG and Spotify Technology SA, as possible targets for new restrictions or fees.

Nana Ama Sarfo explores how some countries are using the revenue results of their digital services taxes — whether better or worse than expected — as justifications for expanding their measures.

Alina Miyake and Lucas de Lima Carvalho explore Brazil’s signing of the OECD multilateral instrument and the implications for Brazil's tax treaties.

Vietnam’s National Assembly has amended the Tax Administration Law to require online platforms to remit taxes on behalf of parties selling goods and services over their systems.

France's Directorate General of Public Finances has published a user guide for taxpayers required to file information returns under the country’s global anti-base-erosion rules, confirming plans to open a submission platform by May 2026.

The Australian Taxation Office has released final guidance on how it will grant full or partial exemptions for public reporting of multinational enterprises' tax information on a country-by-country basis.

Mukesh Butani, Shankey Agrawal, Harsh Shukla, Pratha Khanna, and Spandana Koona examine the impact of U.S. tariffs on global trade and offer recommendations for establishing treaty standards to protect against future uncertainties.

The OECD on December 9 published its 2025 tax revenue statistics report, finding that the average tax-to-GDP ratio across member jurisdictions increased from 33.7 percent to 34.1 percent between the 2023 and 2024 financial years, with social security contributions and personal income taxes accounting for the largest shares of revenue on average in 2023 at 25.5 percent and 23.7 percent, respectively.

This third piece of a series comparing Canada and US individual and business tax rules analyzes how Canada’s Nov.4 federal budget provisions affect the comparisons of Canada’s tax rules to their US counterparts. Draft legislation (Bill C-15 issued on Nov. 18 ) reflects some of the budget proposals and the balance will be dealt with in subsequent legislation, and tax changes are generally prospective not retroactive.

A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration’s aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026.

Belgian Finance Minister Jan Jambon said the EU's evaluation of pillar 2 must account for the major political changes now underway around the world.

Michael N. Kandev examines current transfer pricing guidelines in Canada and compares them with proposed changes in the 2025 budget.

Mindy Herzfeld examines the headwinds facing the OECD pillar 2 global minimum tax project.

The Netherlands recognizes the importance of favorable treatment of substance-based nonrefundable tax credits under OECD global minimum tax rules, but restrictions are necessary to preserve pillar 2’s goals, a top Dutch tax official said.

 The following amicus curiae brief was filed with the Court of Justice of the European Union on November 19 by an international group of tax professors regarding a U.S. business lobby group’s legal challenge against Belgium’s undertaxed profits rule in American Free Enterprise Chamber of Commerce v. Ministerraad, C-519/25.

The OECD plans to soon focus on global mobility and helping tax systems adjust to remote working, Manal Corwin, director of the organization’s Center for Tax Policy and Administration, said. 

Nana Ama Sarfo discusses how the Trump administration’s efforts to combat discriminatory unilateral measures in the digital economy are extending past digital services taxes and including indirect taxes like value added taxes.

The U.K. government has confirmed it is now targeting 2027 for the implementation of OECD pillar 1 reforms that would require the rollback of digital services taxes, citing a delay in negotiations.

House Republican taxwriters revived a threat to institute retaliatory international taxes if global powers don’t show progress on the agreement to exempt American companies from some OECD global minimum tax rules by the end of 2025.

South Korea’s National Assembly has passed legislation increasing each of the country’s four corporate tax rates by 1 percentage point and establishing a tax scheme for “high-dividend companies" meant to revitalize capital markets.

Reuven S. Avi-Yonah examines the legislative history of the net controlled foreign corporation tested income and corporate alternative minimum tax regimes to determine whether pillar 2 can survive side by side with them.

It is vital that an international tax deal be promptly finalized to “provide certainty for U.S. companies and fair treatment for foreign companies who wish to invest in the United States,” House Ways and Means Tax Subcommittee Chair Mike Kelly, R-Pa., said in his opening statement at a December 3 hearing on global competitiveness.

A majority of people in Asia support tax incentives to attract multinational companies and view global tax cooperation as important, according to a newly published survey by the OECD.

 The United Kingdom will proceed with legislation to reform the country’s transfer pricing, permanent establishment, and diverted profits tax rules, while a matrix for related-party transactions will need to be significantly fleshed out through secondary legislation.

The OECD Global Forum on Transparency and Exchange of Information for Tax Purposes on December 2 published its 2025 annual report detailing the current progress on its cross-border administrative transparency initiative across 172 member jurisdictions, finding that over 32,000 information requests were sent during the 2024-2025 fiscal year and that over 70 jurisdictions are committed to implementing the cryptoasset reporting framework and sending out their first exchange requests by 2027.

House Ways and Means Committee Chair Jason Smith (R-Mo.) fired a warning shot to countries negotiating a revised global minimum tax deal at the OECD, vowing to take action if there’s no agreement to exempt US companies from the tax.

Three European countries are progressing with the implementation of global minimum tax rules, with Switzerland and the United Kingdom amending their pillar 2 laws and Montenegro consulting on draft pillar 2 legislation.