Int'l Tax News

Teaser: The article discusses the European Commission’s warning that OECD pillar 2 simplification efforts must remain compatible with the EU pillar 2 directive because there is no short-term plan to amend the directive. Additional simplification may be possible through safe harbors, but only if those safe harbors fit within EU law, including Article 32 and the framework used for the U.S. side-by-side package.

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The growing web of circular deals among billion-dollar companies funding AI’s explosive growth is feeding investor worry about a massive bubble. For corporate tax departments there’s another concern, maybe unrecognized: the risk of transfer pricing regulation.

The UK government defended its digital services tax as an appropriate measure for taxing businesses in the wake of fresh tariff threats from the Trump administration.

This article examines the aftermath of invalidated U.S. tariffs and the government’s refund process, highlighting how repayments are directed to businesses rather than consumers who bore much of the economic burden. It raises important questions about the incidence of tariffs and the distributional consequences of trade policy.

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The article argues that the original policy justifications for the U.K. digital services tax have weakened because BEPS reforms, U.S. international tax changes, and the implementation of pillar 2 have substantially changed how large digital multinationals report and pay tax. It criticizes the DST as an extraterritorial gross-receipts tax that functions more like a tariff or back-door VAT, creating trade friction with the United States while sitting uneasily with treaty-based income tax principles.

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Failure to find a multilateral solution on the taxation of the digital economy would make fresh regional or unilateral measures “almost unavoidable,” a senior European Commission official said.

The European Commission’s coming tax simplification package will reduce the administrative burdens on companies that have signed up to the global minimum tax deal, a top official said.

This article explores how geopolitical conflict is influencing tax policy debates in Australia, particularly regarding the taxation of natural resource exports. It focuses on whether current tax regimes adequately capture revenue from multinational energy companies.

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President Donald Trump sent what might be construed as a chilling message to the thousands of American importers applying this week for refunds for his illegal tariffs: In his eyes, you might fare better if you don’t.

Countries involved in international tax talks at the OECD are working to develop permanent tests to ease compliance with the global minimum tax, a US Treasury official said.

The article says the European Commission cannot estimate revenue losses from the pillar 2 deal and notes that the global minimum tax aims to limit tax competition, not raise revenue. It also addresses member state requests for delays, possible simplifications to tax directives, and challenges in adapting dispute-resolution mechanisms for pillar 2 cases involving non-EU countries.

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EU countries are poised to approve a bill giving the bloc’s anti-fraud agencies access to tax data after amendments were added to ensure privacy rules.

Teaser: An OECD official said the pillar 2 side-by-side package will likely not be reversed at the 2029 stock-take. This means special treatment for U.S.-parented multinationals may remain in global minimum tax rules.  

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Brazil’s tax authority seeks comments on draft changes to its domestic top-up tax to adopt the OECD Pillar 2 safe harbor. The top-up tax could drop to zero for qualifying incentives, up to a limit based on payroll, depreciation, or eligible assets. This aligns Brazil's rules with the OECD, while preserving space for tax incentives under the global minimum tax.

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Teaser: Luxembourg's tax administration will apply the OECD’s Amount B simplified transfer pricing approach to treaty jurisdictions. For in-scope marketing and distribution, Luxembourg may refrain from adjusting pay, provide a matching adjustment, or use MAP relief. This supports the political commitment, aims to reduce the risk of double taxation, and to improve certainty.

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This article analyzes the implementation of the tariff-refund process following the Supreme Court’s invalidation of key U.S. tariffs. It highlights administrative uncertainties, compliance challenges for importers, and the broader implications for trade enforcement and revenue recovery. The piece is particularly relevant for understanding how tariff measures function as tax-like instruments and how their reversal affects cross-border transactions and regulatory practice.

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Countries are leaning toward further engagement in digital tax talks, a top OECD official said.

Brazil is awaiting OECD action on its request for exemption from key parts of the global minimum tax framework, following a similar carve-out secured by the US for its multinationals.

The OECD is working on guidance this year that would aim to prevent companies from abusing new global minimum tax rules, a top official said.

The next five years are crucial in preserving progress on multilateralism, a top OECD official said as she laid out the case for further global tax cooperation after January’s landmark minimum-tax deal.

Countries involved in global tax talks at the OECD are developing a process to determine whether jurisdictions have appropriately applied the global minimum tax rules into their local laws.

Recent changes to the global minimum tax framework still give countries ample latitude to offer multinational companies beneficial tax incentives, an OECD official said.

The European Union needs to be more ambitious in its aims to simplify rules for businesses, including by reforming the bloc’s tax system, according to Ludovit Odor, a European representative from Slovakia.

Professor Herzfeld examines the United States’ withdrawal from United Nations tax negotiations, contending that while U.S. objections to the process are valid, nonparticipation diminishes its capacity to influence the development of international tax norms. Herzfeld further explains that the U.N.’s framework convention initiatives, the Sevilla commitments, and the Tax Committee agenda collectively promote a shift toward greater source-based taxation, particularly regarding cross-border services, digital activities, and permanent establishment rules. This positions the U.N. tax project as a significant competitor to the OECD-centered system and suggests that continued U.S. nonparticipation may weaken dispute resolution mechanisms, deter foreign direct investment, and erode long-term U.S. economic influence abroad.

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Iran’s proposal to impose transit fees on vessels passing through the Strait of Hormuz reflects a broader historical pattern of states attempting to monetize control over key maritime chokepoints. The article traces similar practices from Ottoman and European regimes, highlighting how tolling waterways has long been tied to assertions of sovereignty and economic leverage. The current situation raises significant questions under international maritime law, particularly regarding the legality of charging fees for passage through straits used for international navigation, and underscores the geopolitical and economic risks such measures pose to global energy markets and shipping.

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This article examines ongoing legal challenges to the Trump administration’s tariffs on imports, highlighting disputes over executive authority and trade policy. The litigation reflects broader tensions in international economic law and raises questions about the use of tariffs as quasi-tax instruments in cross-border regulation.

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New corporate tax disclosures will provide investors with some answers to the persistent puzzle of where companies book their profits and pay their taxes—but some pieces of the puzzle are still going to be missing.

This article analyzes the development of post-pillar 2 business incentives in the Swiss canton of Zug, focusing on efforts to comply with GLOBE rules that prohibit related benefits and may jeopardize eligibility for a domestic minimum top-up tax. Wenz and Kaiser observe that Zug transitioned from income-based incentives to expenditure-based subsidies, although certain elements may continue to generate uncertainty during peer review. This case demonstrates the influence of pillar 2 on subnational tax competition and incentive strategies, especially in low-tax jurisdictions seeking to maintain competitiveness without risking disqualification under the OECD framework.

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This article examines how rising tariffs on Chinese imports have led to widespread trade fraud and accounting manipulation, as firms attempt to circumvent higher duties. It highlights practices such as misclassification of goods and rerouting through third countries, raising significant enforcement challenges. These developments are directly relevant to international tax and trade compliance, as tariff avoidance strategies often intersect with transfer pricing and customs valuation issues. The piece underscores how increased trade barriers can distort reporting and complicate cross-border regulatory enforcement.

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OpenAI published a policy blueprint for artificial intelligence recommending a revised social contract to prepare for the technology’s likely impact on the economy, workforce and overall state of humans.

Avi-Yonah argues that a corporate wealth tax is more feasible than an individual wealth tax, as it addresses the mobility and valuation challenges that hinder the direct taxation of wealthy individuals. Avi-Yonah further explains that this tax could be structured as a constitutionally valid excise on corporate operations, coordinated internationally through a pillar 2-style framework, and credited against the corporate income tax. This approach offers an alternative for taxing concentrated corporate wealth and prompts reconsideration of the relationship between wealth taxation and the existing corporate income tax.

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The Trump administration is preparing to outline a tiered system for its broad tariffs on steel and aluminum products in an attempt to simplify a process that has dogged American companies for months.

American companies with a big global footprint are reconsidering their debt strategies in the US after a change in Republicans’ 2025 tax law that limits their ability to deduct interest expenses.

Consensus on an international agreement for taxing the digital economy has greatly weakened among countries, a top French tax official warned.

This article explores how countries are leveraging strategic economic “choke points” to counter U.S. trade policies, including restrictions on critical supply chains and financial flows. It highlights the growing use of economic tools as geopolitical leverage, with implications for global trade and cross-border investment. These developments are relevant to international tax because shifting supply chains and geopolitical fragmentation can affect where profits are earned and taxed. The piece provides useful context for understanding how global tax systems respond to increasingly politicized trade environments.

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The Trump administration is set to announce tariffs on drugmakers that haven’t struck deals guaranteeing low prices in the US, according to people familiar with the plan, the latest move to tax imported goods on national security grounds.

Multinationals in the world’s largest economies are facing several unanswered questions and possible audit scrutiny as they prepare to file their first global minimum tax forms ahead of a fast-approaching June deadline.

Canada is overhauling its rules governing intercompany transactions, handing the tax authority greater powers to adjust corporate tax bills.

Tax officials from developing countries said that United Nations tax reform efforts could help them meet targets under a global financial development plan.

A United Nations group of tax experts approved plans to help developing countries increase the ways they tax high net-worth people.

For years, US multinational companies routinely placed their global intellectual property in affiliates in low-tax jurisdictions outside the US. This may no longer become routine.

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.

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Developed countries in United Nations tax-treaty negotiations have shown an appetite for new approaches to taxing the digital economy, opening some potential for agreement with developing nations that are spearheading the UN talks.

This article examines how major U.S. corporations, including Nvidia, are disclosing large tax payments while also utilizing international tax strategies in jurisdictions like Ireland and Malta, highlighting ongoing issues in corporate tax transparency and global tax planning.

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This article explores how pharmaceutical companies reduce U.S. tax liabilities by shifting profits to low-tax jurisdictions, illustrating continued challenges in enforcing international tax rules and profit-shifting regulations.

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The WTO warns that prolonged geopolitical conflict could significantly disrupt global trade and economic growth, highlighting broader implications for international economic policy and regulation.

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A multilateral agreement on how to tax big tech companies must happen “this year,” according to a senior European Commission official.