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Int'l Tax News

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Drug Pricing Rules and Tariffs Reshape Transfer Pricing for IP (06/29/2026)

  • By Robin Hart
  • By Arindam Mitra

Recent US policy changes are forcing life sciences companies to rethink core commercial decisions in ways that require a reexamination of how intercompany pricing for intangible property is structured and defended. The policy changes come from two directions: measures designed to reduce US drug prices, such as most-favored nation pricing; and tariffs.

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OECD Projects Less Revenue With Side-by-Side Minimum Tax Package

  • By Stephanie Soong Johnston

An OECD tax official said the side-by-side package's substance-based tax incentive safe harbor—more than the U.S. safe harbor itself—is driving down projected pillar 2 revenue, since it lets jurisdictions use qualified tax incentives to attract investment while capping top-up tax exposure. The OECD plans to release an updated global minimum tax impact assessment incorporating this and other recent implementation data, following its 2020 initial assessment and 2024 working paper.

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ATAD Evaluation Flags General Antiabuse Rule’s Legal Uncertainty

  • By Elodie Lamer

A European Commission staff working document evaluating ATAD found stakeholders view the GAAR's broad, discretionary scope as a source of legal uncertainty, prompting debate over whether Unshell's economic substance criteria should instead be folded into the GAAR or DAC6's hallmark D2—a question the commission has deferred by proposing to address substance via future EU Council implementing acts. The evaluation also flags unresolved tension between the GAAR and pillar 2, with the tax simplification omnibus now clarifying that the GAAR extends to top-up taxes, even as businesses argue CFC rules are increasingly redundant alongside pillar 2.

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U.S. Tariff Threat Looms Over Digital Tax Talks

  • By Sarah Paez

President Trump threatened a 100 percent tariff on any country advancing digital services tax legislation, declaring it would apply immediately and override existing trade deals—prompting the European Commission to defend DSTs as a nondiscriminatory sovereign right and warn it will "respond swiftly and decisively" if the EU is targeted. The clash surfaces just as global digital tax talks resume, with German officials pressing for a coordinated international approach on nexus and profit allocation even as valuation questions grow more complex amid rising AI use.

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Week in Insights: Tax Cuts and Jobs Act Met Its Goal at a Cost (06/28/2026)

  • By Andrew Leahey

new economics paper complicates the story about the Tax Cuts and Jobs Act of 2017. For years, supporters have deemed it a pro-growth success, while critics have called it an expensive giveaway tilted toward corporations and high earners.

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Services Taxation Major Sticking Point in UN Talks, Chair Says (06/26/2026)

  • By James Munson

Disagreements over how to tax cross-border services are proving to be a major hurdle for negotiators working on a United Nations global tax agreement, the head of the negotiating committee said Friday.

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Tax Incentives Continue to Dominate Governments’ R&D Support (06/26/2026)

  • By Ryan Hogg

Government support for research and development through tax incentives has more than doubled over two decades, new OECD data shows.

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Trump Vows 100% Tariff If Countries Impose Digital Services Tax (06/26/2026)

  • By Gabriella Borter

President Trump says any country that imposes a digital services tax on American companies “will immediately be met with a 100% TARIFF” on all goods sent to the US.

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Tax AI Where Profits Are Created, OpenAI Executive Says (06/26/2026)

  • By Somesh Jha

Tax policy for artificial intelligence should focus on where profits are created, a top OpenAI executive said on June 26,2026.

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Trump threatens 100% tariff on any country that imposes digital services tax

  • By Doina Chiacu
  • By David Lawder

This article reports that President Trump threatened a 100% tariff on goods from any country imposing a digital services tax on U.S. companies. The article links the threat to France’s existing digital services tax on revenues from online marketplaces and advertising, as well as broader U.S. objections to European DSTs that the U.S. Trade Representative has argued discriminate against American technology companies.

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Government R&D Tax Supports Doubled in 20 Years, OECD Finds

  • By Sarah Paez

Tax incentives now account for 60 percent of government support for business R&D across OECD countries, up from 28 percent in 2004, according to an updated OECD database covering 56 countries. The data also show R&D tax relief has tripled as a share of government budget allocations, with Portugal, Iceland, the U.K., France, and China leading in tax relief as a share of GDP.
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Trump Threatens 100% Tariff on European Countries That Impose Digital Services Tax

  • By Gavin Bade

President Trump threatened to impose a 100% tariff on goods from any European country that enacts a Digital Services Tax on U.S. tech companies, warning the levy would supersede the existing EU-U.S. trade deal. The threat raises fresh trade tensions a day after the EU approved tariff reductions under that agreement, and comes amid legal uncertainty over whether Trump has the authority to impose such tariffs immediately.
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ECJ Adviser Backs EU Probe Into Mead Johnson Gibraltar Tax Break (06/25/2026)

  • By Jan Stojaspal

The European Court of Justice should back the European Commission’s decision to extend a state aid investigation into whether a Gibraltar entity of the Mead Johnson Nutrition group received preferential tax treatment, an adviser to the court wrote on June 25, 2026.

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Tax Simplification Gains Outweigh Revenue Losses, Hoekstra Says

  • By Elodie Lamer

EU Tax Commissioner Wopke Hoekstra defended the European Commission's tax simplification omnibus, which promises to save companies €8 billion by reducing duplicative reporting and easing pillar 2-related antiabuse obligations, arguing the package's budgetary impact on member states is negligible by comparison. Hoekstra also signaled openness to an EU-wide digital services tax as a potential future revenue source if pillar 1 negotiations fail, while cautioning against reading broader harmonization ambitions into the proposal.
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EU’s DAC Recast Facilitates Future Pillar 2 Reporting Changes

  • By Sophie Petitjean

The European Commission's proposed recast of the EU's administrative cooperation directives would consolidate all DAC rules into a single framework, cut €1.283 billion in compliance costs, and empower the commission to adopt implementing acts to align EU rules with future OECD GLOBE information return updates without requiring unanimous legislative amendments. Key changes include easing DAC6 reporting burdens for pillar 2 in-scope multinationals, raising DAC7 digital platform reporting thresholds, and streamlining DAC4 and DAC9 notification requirements.
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Pillar 2 Reshuffles the Cards of EU Antiabuse Rules

  • By Elodie Lamer

The European Commission's tax simplification omnibus proposes sweeping changes to EU antiabuse rules, including exempting pillar 2 companies from controlled foreign company rules, mandating a €3 million interest deduction threshold, and introducing a full withholding tax exemption on intragroup interest, royalties, and dividends effective 2037. The package also introduces a minimum R&D allowance standard within the ATAD, with the commission citing pillar 2 as justification for rolling back overlapping antiabuse measures that risk creating double taxation.
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Italy Reports DST Surge, Weak Global Minimum Tax Revenue

  • By Matteo Rizzi

Italy's Court of Auditors reported that the country's digital services tax generated €637 million in 2025, a 40 percent increase from the prior year, while its first-year global minimum tax revenue came in at just €46 million against a forecast of €381 million. The report also noted continued growth in Italy's flat tax regime for high-net-worth individuals relocating to Italy, with the annual substitute tax now set at €300,000 following successive increases.
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EU Proposes Tax Simplification Measures in Bid to Boost Business

  • By Saim Saeed

The European Union unveiled a new package to overhaul the bloc’s tax rules on June 24, 2026, the latest effort by Brussels to cut red tape and reduce the regulatory burden on business.

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European Commission proposes landmark tax simplification package to streamline compliance and boost competitiveness

  • By European Commission - Directorate-General for Taxation and Customs Union

This official EU item describes a tax simplification package aimed at reducing compliance burdens and modernising the EU direct tax framework. The proposals would remove withholding taxes on certain cross-border intra-EU payments, streamline the interaction between CFC rules and Pillar Two, strengthen cross-border tax dispute resolution, and simplify reporting obligations under the Directive on Administrative Cooperation, country-by-country reporting, and top-up tax information returns.

To read the full article, click here.

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OECD Aware of Issues With Pillar 2 and Investment Treaties

  • By Sarah Paez

OECD officials and tax experts warned that bilateral investment treaty protections in many countries could complicate or trigger arbitration against states implementing qualified domestic minimum top-up taxes, with one analysis suggesting 90 percent of existing investment treaties could expose such measures to investor challenges. The inclusive framework is working toward a coordinated solution, while multinationals and host countries weigh restructuring investments or renegotiating agreements to avoid disputes.
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AI Has No Place in Global Digital Tax Talks, US Official Says (06/23/2026) Author: Lauren Vella

  • By Lauren Vella

Artificial intelligence doesn’t belong in the OECD-led discussions about taxing the digital economy, the top US delegate to the organization said on June 23, 2026.

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Fragmented Filings Complicated Access to EU Public CbC Data

  • By Elodie Lamer

A Fair Tax Foundation review of 302 EU public country-by-country reports found that only 58 percent of companies complied solidly with the directive, with some multinationals filing fragmented single-country disclosures rather than consolidated group-wide reports. U.S. companies and the pharmaceutical sector were the worst performers, and advocates flagged the lack of a central repository as a significant barrier to accessibility.
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2025 MAP Paradigm Shift: The GATS Carveout and Amount B

  • By Mari Takahashi

Takahashi explores the 2025 updates to the OECD and U.N. model conventions and explains how the codification of the General Agreement on Trade in Services carveout and the standardization of amount B establishes the mutual agreement procedure as a strategic buffer to limit or reduce geopolitical friction.
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OECD to Release Data on Impact of US Global Tax Carve-Out (1) (06/22/2026)

  • By Lauren Vella

The OECD plans to release a report in July on the impact of the global minimum tax following a January agreement that carves out US multinationals from key parts of the minimum levy’s framework.

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EP Political Groups Lament Pillar 2 Side-by-Side Deal

  • By Elodie Lamer

MEPs across all major political groups pushed back on the EU's side-by-side package shielding U.S. multinationals from most pillar 2 obligations, warning it creates competitive disadvantages for European businesses and undermines the global minimum tax framework. Several groups also called on the commission to withdraw or overhaul the BEFIT corporate tax harmonization proposal over its incompatibilities with pillar 2.
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U.N. to Issue Deeper Report on Tax Cooperation Progress in 2027

  • By Sarah Paez

The U.N. and a task force of over 60 international institutions plan to publish a detailed 2027 report tracking countries' progress on the Sevilla Commitment, a 2025 agreement aimed at strengthening tax cooperation and boosting domestic resource mobilization in developing countries. The report will draw on the OECD's global revenue statistics tool to measure progress across commitments including tax transparency, taxation of high-net-worth individuals, and evidence-based tax incentive reform.
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German Ministry of Finance Finalizes Landmark PE Guidance

  • By Alexander F. Peter

Germany released its first major overhaul of permanent establishment administrative guidance in over 25 years, updating a 1999 circular to address digital services, remote work, and complex supply chains. The final version incorporates some stakeholder feedback from a February draft but leaves several issues unresolved, including guidance on partnerships, service PEs, and digital business models.
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Netherlands Holds Back on Taxing Windfall Oil Profits

  • By Olaf Geurts

The Dutch government said it will not impose an additional levy on oil companies' excess profits unless the European Commission puts forward an EU-level proposal, citing legal risks after 33 ongoing challenges to its 2022 solidarity contribution have put €2.7 billion in Dutch revenue at stake. The position leaves the Netherlands at a standstill despite parliamentary pressure to redistribute windfall profits to households amid rising energy prices tied to the war in Iran.
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Coke Takes on IRS With $20 Billion at Stake

  • By Richard Rubin

Coca-Cola and the IRS are heading to the 11th U.S. Circuit Court of Appeals in a long-running transfer pricing dispute over whether the company improperly shifted profits to low-tax foreign subsidiaries through its internal "10-50-50" method. A loss for Coca-Cola could trigger over $20 billion in back taxes, interest, and a higher ongoing effective tax rate, while a win would relieve a decade-long liability and offer reassurance to multinationals facing similar IRS scrutiny.
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Trump Poised to Roll Out New Tariffs as He Refunds the Old Ones

  • By Alicia Diaz

Tariff revenue is now flowing out of the US Treasury’s coffers faster than it’s coming in, with nearly $22 billion in unlawfully collected duties reimbursed to importers in May.

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Corporate Tax Exemptions Most Popular Incentive, OECD Data Says (06/18/2026)

  • By Ryan Hogg

Corporate income tax exemptions remain the most popular investment tax incentive instrument across most of the globe, data compiled by the OECD shows.

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EU Urges Swift Resumption of Global Digital Tax Talks (06/18/2026)

  • By Saim Saeed

A senior EU official on Thursday urged the restart of stalled global digital tax negotiations “as soon as possible,” warning that the issue of untaxed revenue from digital services is unlikely to go away.

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India Wins Over Global Bond Funds With Tax Cut, Aiding Rupee (1) (06/18/2026)

  • By Subhadip Sircar

Global funds are piling into Indian government bonds after New Delhi removed taxes on debt for foreign investors and eased ownership caps, along with moves that have helped stabilize the rupee.

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Switzerland Loses Top Competitiveness Ranking to Singapore (06/18/2026)

  • By Allegra Catelli

Switzerland lost its position as the world’s most competitive economy to Singapore, slipping to third place in the ranking as high US trade tariffs and a strong Swiss franc hurt investment flows.

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Colombia Seeks Shield for Multinationals From Global Minimum Tax (06/18/2026)

  • By Somesh Jha
  • By Saim Saeed

Colombia wants to join the US in having its companies exempted from part of the 15% global minimum tax that dozens of countries have already adopted.

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OECD Planning Tax Morale Dialogue with Regional Administrations (06/18/2026)

  • By Ryan Hogg

The OECD is planning to share documentation on tax morale with several tax administrations in the coming weeks, an official said.

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OECD: Countries Should Assess How Pillar 2 Affects Tax Incentives

  • By Sarah Paez

OECD officials urged governments to reassess existing tax incentives in light of pillar 2, noting that some incentives may be less effective under the global minimum tax framework while others may qualify for favorable treatment. Countries were encouraged to evaluate which incentives benefit in-scope multinationals and consider reforms that align with pillar 2 rules while improving investment certainty and tax policy effectiveness.

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Tax Officials Back Benefits of ‘Amount B’ Transfer Pricing Model (06/17/2026)

  • By Ryan Hogg

Tax administrators vouched for potential benefits that a simplified transfer pricing calculation for baseline marketing and distribution activities could have on tax authority capacity and dispute resolution.

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AI Slashes VAT Non-Compliance Tracking Time, OECD Official Says (06/17/2026)

  • By Somesh Jha

Tax authorities are reporting a significant reduction in time spent tracking non-compliance with payments of value-added tax—from nine months to three—thanks to the use of artificial intelligence, an OECD official said Wednesday.

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Tax Policy as a Catalyst for Innovation: Attracting Talent and Capital to Europe in a Multipolar World, Part 3

  • By Scott Levine

In this final installment of the report, Levine looks at the path forward for the EU to use taxation to support growth and innovation, including enhanced cooperation, and suggests that it look to build on U.S. experience rather than replicate it.

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UK Scales Back New Transfer Pricing Reporting Requirements (06/16/2026)

  • By Somesh Jha

The UK tax authority proposed changes to its planned transfer pricing documentation requirements Tuesday to lighten the administrative burden for multinational companies. The new proposal for documentation under the International Controlled Transactions Schedule, open for public consultation until July 31, also adds targeted rules for the financial sector.

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EU Lawmakers Approve US Trade Deal Ahead of Trump Deadline (2) (06/16/2026)

  • By Jorge Valero

The European Union’s US trade deal is close to being implemented after the bloc’s lawmakers gave their final approval, forging ahead despite ongoing transatlantic trade tensions.

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EU’s Bid to Save Companies Billions in Tax Compliance: Explained (06/16/2026)

  • By Saim Saeed

The EU is preparing an ambitious overhaul of the bloc’s corporate tax rules in a bid to cut red tape and boost the European economy’s sluggish growth.

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OECD Opens Consultation to Refine Digital Platform Reporting

  • By Sarah Paez

The OECD is consulting on amendments to its model reporting rules for digital platforms to reduce compliance burdens for gig and sharing economy operators. Key proposals include raising the low-value seller exclusion threshold to €3,000, exempting certain intragroup platform arrangements, and explicitly excluding pure payment processors from reporting obligations.

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Why Squeezing Big Business Harder Won’t Close the UK Tax Gap (06/15/2026)

  • By Jenny Batchelor

If the UK government is serious about closing the tax gap, it can’t do so by repeatedly squeezing the same companies. There is a more effective path. And it runs through AI.

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Macron Brushes Off Trump’s 100% Tariff Threat on French Wine (1)

  • By Ania Nussbaum
  • By William Horobin

French President Emmanuel Macron refused to drop the country’s digital tax after Donald Trump threatened new tariffs on wine, setting the stage for a confrontation when the two leaders meet at the Group of Seven summit in Evian.

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UN Digital Tax Talks Are Unlikely to Succeed Where OECD Failed

  • By Alan Cole

European countries that once worked to keep the United Nations’ tax negotiations from getting off the ground are now among the most active voices inside them.

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EU to Cut Tax Reporting for Big Multinationals in Overhaul (06/15/2026)

  • By Saim Saeed

The European Commission will propose exempting large multinationals subject to the EU’s 15% corporate minimum tax law from reporting on their cross-border tax arrangements.

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EU Countries Split on Budget Flexibility to Counter Energy Shock

  • By Elodie Lamer

The European Commission proposed allowing EU member states to redirect a portion of their defense-related national escape clause budget flexibility toward energy support measures. Several member states and the European Fiscal Board oppose the move, warning it could compromise the credibility of the EU fiscal framework and crowd out necessary military spending.

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EU Reaches ‘General Approach’ on CBAM

  • By Elodie Lamer
  • By Sophie Petitjean

The EU Economic and Financial Affairs Council reached a general approach to extend the carbon border adjustment mechanism (CBAM) to downstream steel and aluminum products. While a consensus was achieved to begin negotiations with the European Parliament, several smaller and island member states abstained or dissented over inflationary concerns and the rigid criteria of the emergency suspension clause.

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