Int'l Tax News

Addressing U.S. concerns about pillar 2 and stabilizing the global minimum tax are OECD member countries’ first priorities, and a return to discussions on pillar 1 “will come after,” a top OECD official said.

Hong Kong’s legislative council is moving forward with a proposal to use its existing general antiavoidance rule to address arrangements that can potentially exploit Hong Kong’s pillar 2 minimum tax rules.

Miguel Cortez Pimentel and Joana Sobral examine the practicalities of the European Council directive on faster and safer relief of excess withholding taxes (FASTER).

German state finance ministers have asked the federal government to ensure that the global minimum tax rules under pillar 2 of the OECD’s two-pillar tax reform plan won’t leave German companies at a competitive disadvantage.

Poonam Khaira Sidhu examines the potential effects of the United States’ lack of participation with pillar 2.

The latest section of House Republicans’ reconciliation tax bill revives proposals to allow the United States to retaliate against what Republicans call discriminatory extraterritorial taxes, this time explicitly referencing digital services taxes and undertaxed profits rules.

The European Commission said it will work to avoid a fragmented situation on pillar 2 that would lead to a “bureaucratic nightmare” for European companies.

Muhammad Ashfaq Ahmed examines the title change of the U.N. Model Double Taxation Convention Between Developed and Developing Countries to the U.N. Model Tax Convention.

The OECD has released an updated consolidated commentary to the global anti-base-erosion model rules under pillar 2 of its two-pillar global tax reform plan, incorporating three years’ worth of administrative guidance.

Katherin Díaz Velilla explains the OECD’s and U.N.’s approaches to creating an international tax framework and shows how developing nations and Latin American countries will play an important role in the U.N. approach.

Treating the global intangible low-taxed income regime as an income inclusion rule and extending the transitional undertaxed profits rule safe harbor won’t be sufficient to address U.S. concerns about pillar 2, a Treasury official said.

A former Treasury official expressed hope that the Trump administration’s tariffs, though ill-advised, could spur policymakers to give more credence to the merits of a consumption-based tax in the United States.

 The government has formed a working group to clarify application of a long-dormant antiabuse statute to a check-the-box election, according to a Treasury official.

Reuven S. Avi-Yonah and Doron Narotzki examine how the history of the United States’ relationship with the global economy could offer insight into innovative tax options in the current economic environment.

Carrie Brandon Elliot interviews four tax professionals to discuss the status of amount B in their respective jurisdictions and compliance suggestions for taxpayers.

R. Glenn Hubbard examines a GOP tax bill that could curb the fears of President Trump's tariffs with a pro-growth tax policy that advances the Made in America agenda. 

While statutory tax rates in the EU declined only slightly in 2014-2022, countries increasingly relied on base-narrowing measures, a trend that will require reconsideration of tax incentives under pillar 2, the EU Tax Observatory warned.

Proposed amendments to a draft report on the role of simplification in EU competitiveness swing between preserving the OECD tax agreement and safeguarding the EU directive.

The Kenyan government is aiming to expand the scope of its significant economic presence tax to tackle the digital economy despite ongoing negotiations on OECD pillar 1 tax reforms, practitioners said.

Mindy Herzfeld examines tax options that could raise sufficient revenue to rescue the United States from its deficit

Lucas de Lima Carvalho explains the legal and policy motives behind Brazil’s digital "detox" tax and considers whether the tax is the right tool for the job.

In a letter to the editor, Jefferson VanderWolk asks whether it’s time to reconsider the global minimum tax.

Robert Goulder comments on the U.S. trade representative’s 2025 National Trade Estimate Report.

EU member states are brainstorming ideas for new own resources for the EU budget, including external border taxes and regulations such as the undertaxed profits rule under the OECD's pillar 2 global minimum tax framework.

Allison Christians provides a history of tariffs in the United States, explaining how both extremes of protectionism and liberalization have affected trade and the economy overall.

The EU tax community generally believes that options laid out by the EU Council’s Polish presidency to allay U.S. concerns about the OECD's pillar 2 minimum tax rules could be used in tandem.

Mindy Herzfeld examines the history of the base erosion and antiabuse tax and considers options for its future.

Błażej Kuźniacki examines the interplay between taxation and international law by considering possible U.S. defense measures against the UTPR (formerly known as the undertaxed payments rule) and digital services taxes.

The U.N. tax convention negotiations should build on what was achieved in the OECD two-pillar plan discussions and implementation, according to South Africa's finance minister.

The EU Council’s Polish presidency reportedly has proposed three options to assuage U.S. concerns about the OECD's pillar 2 minimum tax rules.

Reuven S. Avi-Yonah examines the history of IRS transfer pricing enforcement to provide context for the Coca-Cola litigation.

Developing countries should adopt taxes aimed at the digital economy, including digital services taxes, and band together to resist external threats against those measures, the South Centre told G24 nations.

The IMF has released a communiqué from the G24 regarding the navigation of international economic affairs among geopolitical and trade conflicts emerging from announced tariff policies; the communiqué notes that G24 members and the IMF are committed to working together to increase funds and promote sustainable, efficient tax reforms.

Tax incentives represented more than 50 percent of all government support for business research and development across most OECD countries and other major economies in 2023, according to OECD analysis.

Bertin Kiénou examines the terminations of double taxation agreements with France by Burkina Faso, Mali, and Niger, and he explains how they could be harbingers of the future if unfair tax treaties are not renegotiated, particularly those involving the Global South.

Finding a politically acceptable and stable coexistence between the U.S. global intangible low-taxed income regime and the OECD pillar 2 rules is the Trump administration’s priority in OECD tax reform talks, a Treasury official said.

The United States and Italy have agreed that there should be a “non-discriminatory environment” for digital services taxation to encourage innovative tech company investment.

Karl Berlin explains the potential difficulties in taxing shipping income and vessel sales under the OECD’s pillar 2.

The White House has issued a joint statement with Italy regarding the United States and Italy's cooperation on a mutually beneficial partnership, noting that the two countries are prioritizing nondiscriminatory digital services taxation to attract technological investments.

Ryan Finley explains why the United States’ “reciprocal” tariff policy and U.S. tax unilateralism are a bad combination.

Members of the OECD inclusive framework on base erosion and profit shifting want to work with the United States to find a way forward on global minimum tax rules, the OECD’s tax head said.

EU ambassadors have asked the high-level working party on tax questions to discuss pillar 2 of the OECD’s global corporate tax project in light of the United States’ disengagement and to work out policy options.

Doubts have emerged about the compatibility of the pillar 2 administrative guidance released by the OECD inclusive framework in 2023 and 2025 and the EU’s pillar 2 directive, which was approved in 2022, observers say.

The United States has opened tariff investigations into pharmaceutical products and semiconductors to examine and resolve potential threats to national security.

Small, vulnerable countries should be exempt from new U.S. “reciprocal tariffs” because the new measures could devastate their economies without meaningfully affecting U.S. trade deficits or increasing U.S. revenue, according to a U.N. department.

Danielle Rolfes, Casey Caldwell, and Alistair Pepper explore some of the key issues presented by four retaliatory tax measures now under consideration by President Trump and Congress to respond to discriminatory or extraterritorial taxes imposed by foreign countries.

Antonio Lanotte explores the development of digital technologies in the EU as a means to boost sustainable competitiveness, support innovation, and drive a clean transition.

The U.N. Conference on Trade and Development published a report on April 14 analyzing the potential impact of U.S. tariffs on small and developing countries, including information on how more vulnerable countries would not significantly affect the United States' additional tariff revenue collections but would be disproportionately affected by high tariff rates.

Lee A. Sheppard examines the implications of the Trump administration’s tariff policy.

Jurisdictions in the OECD inclusive framework on base erosion and profit shifting, including the United States, have confirmed they will keep going with negotiations on the OECD’s plan to revamp the corporate tax system.