Int'l Tax News

The OECD's July 21 Corporate Tax Statistics report found average statutory corporate tax rates across inclusive framework jurisdictions held steady at 21.2 percent, matching 2025 and signaling an end to the decades-long global race-to-the-bottom trend, with 113 jurisdictions now at lower headline rates than in 2000. The report flagged a slight uptick in indicators suggestive of profit-shifting mismatches—more pronounced in investment hubs—while corporate tax revenues as a share of GDP dipped slightly from 2022 but remained above pre-pandemic and pre-2008 crisis levels.

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Poland's DST bill will soon enter formal legislative process after weeks of consultations, Deputy Digital Affairs Minister Dariusz Standerski said July 19, with the government projecting roughly PLN 1.7 billion ($448 million) in first-year revenue, rising to PLN 3 billion in later years. Despite U.S. retaliation threats and President Nawrocki's anti-tax campaign pledge, Standerski framed the levy as targeting undertaxed digital business models broadly—not just U.S. firms—while offering relief mechanisms letting companies offset DST liability against corporate income tax already paid, plus investment and R&D credits.

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Shaheen questions the legal basis for elements of the 2022 foreign tax credit regulations, supporting the reconsideration of the regs by Treasury and the IRS.

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A major cryptocurrency trade group is asking an Illinois court to block the nation’s first state tax on digital asset transactions, describing it as discriminatory, unconstitutional, and prohibited under federal law.

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The OECD is planning a framework that would reduce the number of corporate audits. But this hardly turns a blind eye to potential misbehavior. Instead, it recognizes a new approach between governments and large multinational enterprises based on greater transparency and mutual respect.

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Investors and tax-advocacy groups have long suspected that companies use “tax havens” to cut their tax bills — parking profits in or shifting profits to countries with low tax rates or no taxes at all. Now they’re getting some evidence of who might be doing it, and where.

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The OECD convened more than 50 officials from finance ministries and tax administrations across the Asia-Pacific region to discuss implementation of Amount B. The roundtable addressed its potential benefits and implementation challenges, impact-assessment tools, and technical assistance aimed at improving tax certainty and reducing administrative and compliance burdens, particularly for low-capacity jurisdictions.

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A July 17 IMF working paper found destination-based VAT is the "most coherent and least distortionary" way to tax cross-border digital services, capable of raising up to 12 percent of tax revenue in advanced economies versus less than 0.1 percent from DSTs. The paper examined alternatives like nexus rules, U.N. treaty provisions, and withholding taxes, concluding that without deeper multilateral reform, countries will keep layering "imperfect adaptations" onto the existing system.

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A U.N. draft protocol published July 20 would bring automated digital services—including online advertising, social media, search engines, and online gaming—into scope of source-based taxation, allowing states to levy gross-basis taxes on income paid to residents of other signatory states. The draft, alongside a companion protocol on dispute resolution, will be discussed at the next U.N. negotiating session in New York August 3-14, as delegates work toward finalizing a framework convention and early protocols by late 2027; it would also explicitly cover existing DSTs and equalization taxes with similar economic effect.

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The IMF on July 17 published a working paper on the taxation of cross-border services and the various tax instruments that international governments utilize, finding that governments that rely on destination-based taxation better approach issues that come from digital services trade.

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The U.N. has released its latest draft of the framework convention on international tax cooperation, including new measures that establish a fair allocation of taxing rights across participating jurisdictions to reduce double taxation risks; prevent tax avoidance and evasion activities from high-net-worth individuals; focus on tax-related illicit financial flows; promote mutual administrative assistance; support the effective prevention and resolution of taxpayer disputes; and establish information exchange procedures.

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Karan Bhatia, Google's global head of government affairs and a former deputy USTR, argued in a July WSJ op-ed that the Trump administration's digital trade agreements with countries like Indonesia, Cambodia, and Malaysia are building the foundation of a modernized global trading system for the AI era, addressing 146 digital barriers across 43 jurisdictions identified by the USTR, including discriminatory digital taxes and data localization rules. Bhatia urged the administration to enforce existing commitments and expand the roughly 20 countries that have accepted core digital trade principles into a unified framework rather than a fragmented patchwork of bilateral deals.

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Hoor explores the European Commission’s proposed tax omnibus directive, arguing that it will undermine tax sovereignty within the EU and that member states should reject it.

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On a frigid Thursday last December, 50 finance and technology experts shuffled into the International Monetary Fund’s Washington, DC, headquarters with a dire mission: to war-game how artificial intelligence might upend the global economy.

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The United Kingdom HM Revenue and Customs July 13 issued a policy paper on proposed finance bill measures to implement the OECD side-by-side package and updated administrative guidance to the Pillar 2 Global Anti-Base Erosion (GloBE) Model Rules, for purposes of the multinational top-up tax (MTT) and domestic top-up tax (DTT) for multinational enterprise (MNE) and large domestic groups with annual global revenues exceeding 750 million euros (US$858.8 million). The proposal includes measures to: 1) introduce side-by-side, ultimate parent entity (UPE), substance-based tax incentive, and simplified effective tax rate (ETR) safe harbors; 2) extend the transitional safe harbor election to accounting periods beginning on or before Dec. 31, 2027, and ending on or before June 30, 2029, effective for accounting periods beginning on or after Dec. 31, 2023; and 3) amend rules for discontinued operations, companies in distress, the election to treat certain top-up amounts as zero, and DTT determinations for group members. [United Kingdom, Government Portal, 07/13/26] .

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This OECD announcement presents updated analysis of the economic impact of the Global Minimum Tax, combining new estimates with preliminary evidence from its first year of implementation. It highlights expected increases in multinational effective tax rates, reductions in tax rate differentials and profit shifting, and higher global corporate income tax revenues, while preliminary 2024 data show no statistically significant negative effects on investment or employment. The announcement also places the findings in the context of BEPS reduction and broader international tax cooperation.

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This official USTR announcement imposes a 25 percent tariff on certain Brazilian imports following a Section 301 investigation into Brazilian trade practices. The investigation addressed measures involving digital trade and electronic payment services, preferential tariffs, intellectual property, ethanol market access, and other cross-border trade issues. The action reflects the use of tariffs and trade enforcement measures in response to disputed foreign economic policies.

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As global competition for mobile capital intensifies, tax administration is increasingly viewed as a core component of a jurisdiction’s investment offering. The UK’s Advance Tax Certainty Service, or ATCS, reflects this shift, positioning tax certainty as a strategic lever to enhance the attractiveness of the UK for major long-term investments.

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The OECD’s agreement to exempt US multinationals from key parts of the global minimum tax framework is expected to reduce revenues generated from the levy.

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The European Commission justified provisions in its tax simplification bill that leave out the largest multinationals from some anti-tax avoidance rules and reporting obligations, arguing that the global minimum tax insures against most forms of tax evasion.

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The UK is proposing to make its windfall profits tax on oil and gas permanent, with a new levy that would extend the windfall beyond its current expiration in 2030.

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The UK released its latest consultation document on the International Controlled Transactions Schedule, or ICTS, on June 16. This new annual filing requirement will transform transfer pricing risk assessments for both the UK tax authority, HM Revenue & Customs, and taxpayers, shifting from a documentation-focused process to a data-driven one.

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Overcoming data access and personnel limitations is among top challenges for a United Nations effort to help developing countries expand their enforcement of transfer pricing in the tech sector.

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Companies should give the OECD’s latest simplification measures time to work after a difficult first year of compliance with the global minimum tax rules, a senior OECD official said.

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UK lawmakers warn that companies still pose “significantly high” risks of diverting profits despite the new global minimum tax deal and asked the tax authority to share progress on implementation within a year.

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Members of EU Parliament adopted a resolution for tax proposals meant to boost competitiveness in the bloc.

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Bonnet and Pletz examine how artificial intelligence and environmental, social, and governance rules may challenge traditional transfer pricing models for central entities in banking groups, and they argue that the changes may require reassessing the transfer pricing remuneration of those entities.

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New tax reporting rules in the European Union for multinationals deter growth and risk creating a “culture of damnation,” according to a US official.

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Hundreds of companies, trade associations and foreign governments are asking for their supply chains to be spared as the Trump administration weighs imposing a new round of widespread tariffs later this month.

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President Donald Trump’s threat to impose 100% tariffs on countries with digital services taxes is an attempt to use consumer-funded trade pain to shield big tech from foreign tax bills, rather than a defense of the US tax system. It would be better to move toward a coherent multilateral framework that trades repeal of unilateral DSTs for clear rules on where digital profits can be taxed.

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A three-day hearing hosted by the US Trade Representative kicks off on Tuesday, bringing together industries and government officials trying to plead their case for or against more tariffs from the Trump administration.

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This post examines digital services taxes in light of broader debates over taxation, digitalization, and artificial intelligence. It discusses DSTs as a response to the stalled implementation of OECD Pillar One Amount A, and considers whether user data, AI-driven monetization, and different digital business models may justify more refined DST rules, including differentiated rates and revised scope for the AI economy.

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Andy Burnham said he would increase business rates on warehouse-based companies in order to lower costs for high street shops and bars as he set out details of what he would do if he continues on his path to becoming the next prime minister.

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An ambitious project to strengthen European countries’ resolution of cross-border tax and transfer pricing disputes—if it fulfills its vision—will pay off with upgraded standards, faster processes, and more certainty for multinational companies, tax professionals say.

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Irish corporate tax receipts rose in the first half of the year, despite concerns that American firms would reshore profits as part of President Donald Trump’s vow to bring US company profits home.

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This piece discusses President Trump’s threat to impose a 100 percent tariff on countries that apply digital services taxes to U.S. companies. It explains that the administration would likely need to proceed through established trade-law mechanisms, such as Section 301 or Section 232 investigations, and places the proposal within broader U.S. objections to foreign DSTs targeting American technology companies.

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The European Union should include a digital levy targeting large tech companies as it searches for new revenue to finance defense spending and repay joint debt, Czech representative Danuše Nerudová said on July 2, 2026.

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A group representing Europe’s biggest companies called on EU governments July 2, 2026 not to water down the European Commission’s tax simplification bills, warning that changes could undermine efforts to reduce regulatory burdens and boost the bloc’s competitiveness.

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The first public country-by-country reports under the EU directive—from Microsoft, Procter & Gamble, and others—drew praise for transparency but warnings from the OECD, business groups, and companies against misreading the data. Microsoft booked 38.1 percent of its worldwide profits in Ireland despite housing under 3 percent of its workforce there, while P&G reported $114 million in tax-free Luxembourg profit tied to a now-liquidated entity, fueling debate over whether the disclosures reveal avoidance or just an incomplete picture.

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The International Tax Observatory on July 20 issued a policy note regarding the relationship between the OECD's pillar 2 tax regime and controlled foreign corporation rules, finding that pillar 2 should complement CFC rules and that both should address different types of tax avoidance within the EU's overall corporate tax framework.

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Some corporate tax incentives doled out by Latin American countries significantly reduce their effective tax rates, a new report from the OECD found.

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Germany's Bundestag Finance Committee rejected a Greens proposal for a 10 percent digital services tax on big tech, whose German effective tax rate runs about 3.4 percent versus up to 30 percent for domestic firms; the CDU/CSU cited legal concerns and the SPD called it premature. The Greens vow to keep pushing, preferring a coordinated EU-level DST over the U.S.-secured pillar 2 carveout.

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Microsoft's first public country-by-country report under new EU disclosure rules shows the company concentrated 38.1% of its global pretax profit in its Irish hub, where it employs under 7,000 people but generates pretax profit per employee 13 times the worldwide average. The disclosure, filed because Microsoft's fiscal year ends in late June, offers an early look at how multinationals structure intercompany transactions across jurisdictions ahead of similar reporting requirements taking effect in Australia and under the FASB later this year.

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Canada’s decision to deviate from global norms in targeting cross-border tax avoidance structures would weaken investment and raise costs for companies, especially those working with entities in the US, tax professionals say.

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