OECD Updates G20 on International Tax Cooperation Developments
The OECD on July 17 published a report — prepared ahead of the July 17-18 meeting of G20 finance ministers and central bank governors in South Africa — regarding recent developments in international tax cooperation, including its support of various G20 priorities such as tax transparency and the implementation of the base erosion and profit-shifting minimum standards.
U.N. Tax Protocol on Services Could Build on Amount A, G24 Says
The U.N. tax framework convention’s early protocol on services should incorporate fractional apportionment or formulary apportionment similar to amount A of pillar 1 of the OECD’s two-pillar global tax reform plan, the G24 said.
Good Intentions, Bad Tools: A Case for Repealing the UTPR
Pramod Kumar Siva and William H. Byrnes explain why the UTPR, formerly known as the undertaxed profits rule, is an unlawful extraterritorial tax that contravenes legal norms, generates economic distortions, and diminishes international tax cooperation.
Four in Five Polled Europeans Want MNEs to Pay Minimum Taxes
A new Eurobarometer shows that 80 percent of Europeans polled want large multinational enterprises to pay a minimum amount of tax in each of their countries of operation, an idea that finds a majority in all member states.
U.N. Model Tax Convention 2025: New Wine in New Bottles – But What’s Really New?
Muhammad Ashfaq Ahmed examines changes to the U.N. Model Tax Convention 2025 from their genesis, evolution, and development, to their finalization, approval, and future implications from both an international tax law and international political economy perspective.
Moving On From Retaliatory Taxes
Mindy Herzfeld examines the developments that led to the recent G7 agreement to respect the U.S. tax regime as “a side-by-side system” with the OECD’s pillar 2 and what that means for the future of digital services taxes and tax multilateralism more broadly.
EU Says GILTI Pushdown Might Defeat Pillar 2 Purposes
The EU has “a quite negative view” on the United States' proposal to credit its minimum tax rules when calculating their qualified domestic minimum top-up taxes under pillar 2, according to a top European Commission official.
Irish Finance Minister Questions What G7 Deal Means for Pillar 2
Irish Finance Minister Paschal Donohoe said there are still outstanding questions about how the G7 deal on pillar 2 will affect competition between the EU and the United States and the future of the law.
European Parliament to Examine a Levy on Artificial Intelligence
The European People’s Party's advocate for copyright issues in the European Parliament has suggested a 7 percent levy on artificial intelligence companies that use copyright-protected works to compensate rightsholders.
BRICS Countries Endorse U.N. Tax Convention Work
BRICS member states said they support work on a U.N. tax convention and its role in promoting better cooperation and transparency to address issues like illicit financial flows and tax evasion by the superrich.
Developing Countries’ Tax Systems Center Stage at U.N. Conference
Several high-income countries and civil society groups committed to improving developing countries' domestic tax systems to increase revenue collection there at a major U.N. development financing conference.
The Rise and Stall of the EU’s State Aid Campaign Against Transfer Pricing
Shafi U. Khan Niazi and Richard Krever examine how the European Commission attempted to stop intra-Europe transfer pricing schemes by reversing private rulings that facilitated profit shifting through preferential tax treatment in the profit destination jurisdictions.
EU Commission Doesn’t Foresee Need to Change Pillar 2 Directive
The European Commission says the G7 provisional agreement on pillar 2 is based on a permanent safe harbor shielding U.S. firms, but the lack of details leaves stakeholders drawing various conclusions.
U.N. Tax Convention Work to Focus on Cross-Border Taxing Rights
The U.N. committee negotiating a framework convention on international tax cooperation will focus on the fair allocation of taxing rights — especially over multinationals — and the prevention and resolution of tax disputes at its next sessions.
Two if by Sea: The Role of Tax in the U.S. Shipping Revolution
Guy A. Bracuti examines President Trump’s Executive Order 14269, “Restoring America’s Maritime Dominance,” and the tax provisions of the Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025.
G7 Deal Shields U.S. Firms From Some Pillar 2 Minimum Tax Rules
The United States’ G7 counterparts have agreed to not apply their pillar 2 global anti-base-erosion (GLOBE) rules to U.S.-parented groups, but those companies would still be in scope of qualified domestic minimum top-up taxes.
The Logic of the Revenge Tax
Wei Cui argues that the One Big Beautiful Bill Act’s formerly proposed section 899, targeting “unfair” foreign taxes, was more sensible than many observers initially perceived, and that, if seen as a restrained deployment of U.S. market power, it represented a defensible and ultimately acceptable approach for addressing the undertaxed profits rule and digital services taxes.
Senate Fixes to the House Bill and More
Mindy Herzfeld examines the changes made by the Senate to some provisions of the One Big Beautiful Bill Act, saying that the Senate’s version of the bill improves on the retaliatory tax measures introduced by the House and would simplify and improve the U.S. international tax regime.
Frankenstein-Pay: Does PayPal’s 95 Percent Foreign Income Since 2013 Cause a Monstrous Periodic Adjustment? Part 2
Stephen L. Curtis continues his analysis of PayPal’s cost-sharing arrangement, explains how the cost-sharing regulations can be exploited to possibly shift billions in U.S. profits offshore with little or no IRS detection or enforcement, and explores how the agency’s position could be changing.
OECD Global Mobility Effort Aims to Ease PE Tax Woes
Employees are increasingly on the move in the wake of the COVID-19 pandemic, and observers say the OECD is well placed to design templates to make it easier for countries, companies, and employees to determine tax residency.
Senate Offers Up ‘Defanged’ Remittance Tax, but Critics Remain
Senate Republicans addressed key concerns about the scope of a proposed excise tax on remittances in their version of the reconciliation tax bill, but the overarching policy still has its detractors.
Senate GOP Opts for International Tax Regime Redesign
Senate Republicans unveiled a robust set of international corporate tax reforms in their version of the reconciliation tax bill, including adjustments to the House-passed version and a suite of new provisions.
MEPs Sink Report on Development Financing Despite Tax Consensus
Members of the European Parliament rejected a report calling for a strong U.N. tax process in the context of the next international conference on financing development, though that specific provision was consensual.
Countries Signal Tax Commitment Ahead of U.N. Finance Conference
U.N. countries agreed to prioritize international tax cooperation ahead of a major development financing conference, with an emphasis on improving domestic resource mobilization for developing countries.