Int'l Tax News

This article examines corporate litigation seeking refunds of tariffs imposed under executive authority later overturned by the Supreme Court. The reporting highlights the fiscal and legal consequences of invalidated cross-border levies, including potential revenue exposure for the federal government and broader implications for the treatment of trade-based revenue measures in international economic policy.

To read the full article, click here (subscription required).

The European Commission launched a consultation on a proposed “tax omnibus” package aimed at simplifying key EU direct tax directives, including the parent-subsidiary, interest and royalties, merger, ATAD, and dispute resolution directives. Officials emphasized that the initiative is intended to reduce compliance burdens while remaining broadly revenue-neutral across member states. Potential reforms, such as aligning CFC rules with pillar 2 and revisiting interest limitation provisions, reflect an effort to streamline EU corporate tax architecture without redistributing taxing rights.

To read more, click here.

Here are the key issues in the court fight over Trump’s newest tariffs after the Supreme Court’s ruling.

The article explains how U.S. tax rules reinforce economic sanctions by denying foreign tax credits under section 901(j) and limiting the foreign earned income exclusion under section 911 for taxpayers connected to certain sanctioned countries. These provisions apply when diplomatic relations deteriorate, when a country is designated a state sponsor of terrorism, or when travel-related transactions are restricted under U.S. sanctions law. The analysis highlights how tax law functions as a supplementary enforcement tool alongside broader national security and foreign policy measures.

Finland, Liechtenstein, and Poland are advancing the implementation of OECD pillar 2 rules, including safe harbor provisions and expanded information exchange requirements. Finland approved legislation incorporating OECD administrative guidance on GLOBE safe harbors, including the side-by-side safe harbor that could exempt U.S.-parented groups from top-up tax. Poland, meanwhile, enacted rules implementing DAC9 to facilitate the automatic exchange of pillar 2 information returns among EU tax authorities.

To learn more, click here.

A senior European Commission tax official rejected concerns that implementing the OECD pillar 2 “side-by-side” package without amending the EU directive creates legal uncertainty or unfair advantages for the United States. The official argued that the directive already provides sufficient flexibility for member states to implement the safe harbor framework tied to jurisdictions with qualifying minimum tax regimes. The discussion reflects broader debates in Europe over pillar 2 implementation, administrative complexity, and coordination among member states on international tax rules such as transfer pricing.

To learn more, click here.

The U.S. Senate advanced the bipartisan HONOR Act, which would deny foreign tax credits and income tax deductions for taxes paid to Russia by U.S. businesses. The proposal would add Russia to the list of countries subject to the section 901(j) foreign tax credit disallowance rules, alongside jurisdictions like Iran and North Korea. The measure reflects growing efforts to use the tax system as a geopolitical tool to discourage economic activity that could support adversarial governments.

To learn more, click here.

This article examines how Colombia’s dividend-triggered corporate tax system interacts with the U.S. foreign tax credit regime for U.S. shareholders of Colombian corporations. Because Colombian tax on certain corporate earnings is deferred until dividends are distributed, U.S. taxpayers may face timing mismatches that prevent effective use of foreign tax credits against earlier U.S. inclusions such as NCTI. The analysis explores alternative characterizations and planning approaches that could mitigate double taxation under sections 901 and 960.

To learn more, click here.

President Donald Trump’s administration started the first of several sweeping trade investigations that set the stage for new tariffs, the centerpiece of a push to replace levies struck down by the US Supreme Court.

Governments worldwide are in a high-stakes competition to lure data centers, the digital factories of the 21st century, using tax incentives, abatements, accelerated depreciation, and energy credits. Around the world, divergent jurisdictions are creating both opportunities and risks. Yet many countries are deploying incentives without clear analysis of long-term fiscal and infrastructural consequences.

Meta announced it will begin charging advertisers location-based fees for ads displayed in jurisdictions that impose digital services taxes, including several EU countries, Turkey, and the United Kingdom. The fees correspond to the applicable DST rate in each jurisdiction and are calculated based on where the ad audience or impressions are located. The move reflects a broader trend among large digital platforms such as Amazon and Google that pass DST-related costs on to advertisers operating in affected markets.

To learn more, click here.

The column reviews recent developments in U.S. international tax, including the IRS’s unsuccessful petition for rehearing in the 3M blocked-income case and litigation developments in YA Global concerning effectively connected income. It also analyzes new tax proposals tied to the One Big Beautiful Bill Act and commentary from practitioners on recent IRS notices addressing foreign tax credit timing, subpart F allocations, and sourcing of borrow fees. The discussion highlights ongoing disputes over section 482, international income attribution, and regulatory guidance affecting multinational taxpayers.

To learn more, click here.

The U.K. Court of Appeal held that Muller UK and its related corporate members could not deduct amortization of intellectual property and goodwill transferred into a limited liability partnership. The court concluded that the relevant parties were related for purposes of the Corporation Tax Act 2009, so the transfer did not qualify for the favorable intangible asset regime. The decision reinforces the limits on obtaining corporate tax deductions for intragroup transfers of intangible assets where there is no real change in ownership.

To learn more, click here.

HM Revenue & Customs reported that transfer pricing yield and diverted profits tax receipts reached nearly £3.4 billion and £94 million, respectively, in the 2024–2025 fiscal year. The statistics highlight HMRC’s continued reliance on transfer pricing enforcement, APAs, MAP procedures, and the Profit Diversion Compliance Facility to address multinational profit shifting. The report also notes that the U.K. plans to repeal the diverted profits tax and replace it with the Unassessed Transfer Pricing Profits regime beginning in 2026.

To learn more, click here.

Guernsey announced that territorial corporate tax will no longer be considered as part of its ongoing tax reform review, following industry feedback that emphasized the importance of stability and predictability. The decision reflects the island’s effort to preserve confidence in its tax framework as it seeks to maintain its position as an international finance center. The development highlights how smaller financial jurisdictions are balancing tax reform pressures with competitiveness and the need for policy certainty.

To learn more, click here.

A senior European Commission official promised Wednesday to deliver ambitious legislation meant to simplify the bloc’s tax rules, saying the bill will be “very business-friendly.”

A draft opinion from the European Parliament proposes linking the EU’s 2028–2034 customs and taxation program to the implementation of the OECD/G20 BEPS framework. The report calls for program funding to prioritize coordinated enforcement of the inclusive framework rules, improved tax cooperation, and digital tools to combat cross-border tax fraud and inefficiencies in withholding taxes. Lawmakers also urged stronger transparency and oversight mechanisms to ensure the €6.2 billion program effectively supports EU tax policy objectives.

To learn more, click here.

The Dutch state secretary of finance warned that major legal, administrative, and political obstacles could prevent implementation of a global minimum wealth tax on ultrawealthy individuals. In a letter to parliament, the official highlighted difficulties in obtaining reliable cross-border asset data and noted the absence of international consensus on economist Gabriel Zucman’s proposed 2% “top-up” wealth tax. The comments underscore growing skepticism within governments about the feasibility of coordinating a global wealth tax regime similar to the OECD’s BEPS project.

To learn more, click here.

The Trump administration wants to reassess previous work by countries on taxing the digital economy, the top US negotiator to the OECD said.

Herzfeld argues that international tax policy debates remain focused on the digital economy even as artificial intelligence is reshaping how businesses generate profits. The rise of AI challenges core tax concepts such as permanent establishment, nexus, and the transfer pricing framework built around DEMPE functions and human value creation. She suggests that massive investments by U.S. tech companies in AI infrastructure and the growing role of proprietary data may require policymakers to rethink how taxing rights and profits are allocated globally.

To read more, click here. 

Several American multinationals are moving forward with plans to bring their valuable intangible property back home, enticed by new tax benefits the US has to offer.

President Donald Trump’s fluctuating tariffs have weighed down US job growth with rising costs and uncertainty for companies, according to a new memo from the group founded by former Vice President Mike Pence.

HM Revenue & Customs released a policy paper outlining reforms to the U.K.’s advance corporation tax (ACT) regime aimed at simplifying the treatment of surplus ACT balances. The measure will remove the “shadow ACT” rules that previously restricted companies’ ability to offset unrelieved ACT balances against corporation tax liabilities. Effective for accounting periods ending on or after April 1, 2026, the reform is expected to simplify corporate tax compliance and allow companies to utilize remaining ACT credits more efficiently.

To read more, click here.

A judge’s decision has raised hopes for businesses seeking refunds on tariffs they paid, but it may take months before companies actually receive the money.

EU members are beginning to implement the side-by-side agreement reached by the G7 last year—a deal that put the US and OECD global minimum tax frameworks on equal footing. This is an important step in international economic relations, which have been frayed by hostility over discriminatory policies.

Thousands of companies filed lawsuits to reclaim tariffs after the Supreme Court invalidated the duties, forcing the government to begin refunding billions.

American companies are feeling the pinch of the global minimum tax, but their bills will shrink after a US exemption from the levy kicks in and countries begin to offer new tax incentives to maintain foreign investment.

The president’s flat 10 percent tariff on imports could reshape global trade patterns, benefiting some countries that previously faced higher tariff rates while raising questions about the broader impact on imports.

An industry report shows that tariffs, high interest rates and reduced infrastructure spending are slowing growth and reducing jobs in the heavy equipment manufacturing sector.

Businesses and consumers who paid tariffs on imported goods are now seeking refunds after certain duties were ruled unlawful, highlighting the financial consequences of trade policy decisions.

This article examines who ultimately bears the economic cost of tariffs imposed by the Trump administration and how markets and international trade partners respond to those policies.

In the days since the US Supreme Court declared most of President Donald Trump’s global tariffs illegal, more than 100 companies filed new lawsuits, underscoring widespread concerns that the administration won’t readily refund the billions of dollars it’s already collected.

The article explores the potential awkward legal outcomes of adopting the UTPR as an income tax, which could allow countries to tax activities they do not control or have authorized. The article considers alternative approaches to implementing the UTPR, such as civil penalty regimes or taxing deductible payments, to avoid these inconsistencies. It also examines the practical application of UTPR under the OECD's GLOBE rules and discusses its implications for multinational enterprises, particularly in cases like India, Australia, and Kenya.

To read more, click here.

President Donald Trump effectively upended a global minimum tax deal signed by nearly 140 countries on his first day back in office, declaring other countries shouldn’t decide how US multinationals will be taxed.

This article examines widespread corporate litigation seeking refunds of tariffs imposed under executive authority later curtailed by the Supreme Court. The piece highlights the fiscal exposure facing the federal government and explores how invalidated cross-border levies functioned as de facto revenue measures with significant implications for international trade taxation.

To read the full article, click here (subscription required).

The U.S. is prioritizing guidance related to the OECD's Pillar 2 side-by-side package to ensure efficient global implementation of the GLOBE rules. Treasury official Isaac Wood highlighted the need for clarity in resolving technical gaps, such as those concerning intragroup financing and the side-by-side safe harbor. The U.S. remains heavily engaged in the technical aspects of Pillar 2 to address issues impacting U.S.-headquartered multinational enterprises and ensure alignment with domestic tax laws.

To read more, click here. 

Top negotiators at the United Nations in coming weeks will begin threading the needle between countries’ competing views of a new global tax treaty’s scale of ambition as deadlines for the deal’s first drafts draw near.

The European Commission’s upcoming tax simplification package won’t reopen the bloc’s global minimum tax directive, according to a senior EU official.

Both the Organization for Economic Cooperation and Development, through the Inclusive Framework, and the United Nations, through negotiations for the Framework Convention on Tax Cooperation, are doing serious work in developing the most significant reforms to international taxation in a century.

Companies are clamoring to bring their valuable intellectual property back to the US, as expanded tax benefits and the new side-by-side global tax system make repatriating suddenly more attractive, tax professionals said. But there’s a problem.

In early February 2026, the OECD released an updated edition of its Manual on Effective Mutual Agreement Procedures, consolidating and refining prior guidance on the MAP process through the entire lifecycle of a proceeding under bilateral income tax treaties. This article examines seven key takeaways from the updated Manual, highlighting its implications for tax departments in the current controversy environment. The Manual aims to improve the effectiveness and timeliness of MAP proceedings, potentially allowing competent authorities to focus on more complex disputes.

A US exemption from parts of the revised OECD global minimum tax agreement creates fresh uncertainty for multinationals preparing to file 2026 earnings reports.

October 8, 2021, marked the beginning of the Pillar Two era, when 137 countries (known as the Inclusive Framework and led by the OECD) signed a political agreement to domestically legislate a 15% minimum tax on all profits of multinationals that annually have at least €750 million of gross revenue. On January 5, 2026, the IF (now up to around 150 countries) signed another political agreement (the side-by-side (Sbs) agreement) that should serve to dissolve US objections that had been holding up full international adoption of Pillar Two. This article focuses on how the Sbs agreement affects US multinationals with Canadian subsidiaries.

The Trump administration’s newly floated 0.125% “land port maintenance tax,” pitched as a fix to align shippers using land ports with those subject to the Harbor Maintenance Fee, looks less like infrastructure policy and more like contingency planning now that the US Supreme Court has struck down the administration’s tariff program under the International Emergency Economic Powers Act.

This article examines the I.R.S.’s use of real-world profit data to challenge how Meta values offshore intellectual property for tax purposes. The piece highlights a significant shift in transfer pricing enforcement, with implications for cross-border income allocation, valuation of intangibles, and the taxation of multinational enterprises’ foreign earnings.

To read the full article, click here (subscription required).

Business representatives questioned whether the EU’s tax blacklist and the defensive measures it triggers undermine the bloc’s competitiveness, particularly following Vietnam’s addition to the list. The article examines how denial of deductions, withholding consequences, and treaty interactions create uneven compliance burdens across member states. It also explores the interaction between the blacklist regime and OECD Pillar 2, with companies increasingly using the global minimum tax framework to define low-tax jurisdictions.

To read more, click here.

This article analyzes the administration’s response to the Supreme Court’s ruling striking down core elements of its tariff program. Despite the legal setback, the president signals an intent to maintain aggressive trade measures through alternative mechanisms. The piece evaluates the economic rationale behind the administration’s trade strategy, the legal constraints imposed by the Court’s decision, and the potential consequences for global supply chains and U.S. trading partners.

To read the full article, click here (subscription required).

The Supreme Court’s nixing of US President Donald Trump’s “reciprocal” tariffs is throwing fresh confusion over the raft of trade deals negotiated by global partners as the inescapable reality of ongoing levies remains a threat.

The European Union is poised to freeze the ratification process of its trade deal with the US and is seeking more details from President Donald Trump’s administration on its new tariff program.

This article reviews the legal and structural fallout following the Supreme Court’s invalidation of key Trump tariffs. It discusses the administration’s attempt to rely on alternative statutory authority and considers the broader institutional consequences for U.S. trade powers, global supply chains, and the stability of cross-border fiscal measures affecting international commerce.

To read the full article, click here (subscription required).