2026

The Italian Supreme Court is playing a big role in shaping the country’s intragroup pricing practices, pushing more rigorous economic analysis and better documentation as a steady stream of transfer pricing disputes reaches its docket, tax professionals say.

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Negotiators clashed over whether a draft U.N. tax convention protocol should supersede existing dispute mechanisms or preserve them during August 12-13 talks in New York. While OECD members and several allied jurisdictions advocated for protecting established bilateral procedures, the Africa Group pushed for the protocol to override existing pacts to resolve structural power imbalances; delegates also voiced divergent stances on mandatory arbitration and investor-state dispute settlement despite widespread backing for the mutual agreement procedure.

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The Australian government introduced legislation on August 13 to establish a new bargaining incentive that would impose a 2.5 percent tax on digital advertising revenue for major social media and search platforms that fail to strike commercial content deals with local news outlets. While revised provisions require tech giants to sign agreements with at least eight local publishers to offset liability, U.S. tech trade groups criticized the measure as a discriminatory levy that distorts digital trade and warrants U.S. government opposition.

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The Trump administration can continue to collect tariffs on low-dollar imports after a US trade court rejected a challenge to the president’s policies.

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The European Commission does not share the characterization of its Carbon Border Adjustment Mechanism as a tariff, spokesperson Louise Bogey says at a daily press briefing in Brussels, responding to a question about an FT op-ed from US Ambassador to the EU Andrew Puzder.

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Polish government is conducting “a very complex and sensitive analysis” of a planned digital tax, examining both the details of the levy and its potential impact on relations with the US, Prime Minister Donald Tusk says at press conference in Warsaw.

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Global North and Global South countries clashed over whether cross-border services income should be taxed on a gross or net basis during August 10-11 negotiating sessions on a draft U.N. tax convention protocol. While developed jurisdictions and business groups warned that gross-basis taxation disregards business expenses and distorts cross-border trade, developing countries favored gross taxation for administrative ease while seeking clarity on how to operationalize optional net-basis rules without creating discrimination.

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The OECD should tweak its proposed changes to the rules on how digital platforms in the sharing and gig economy share information with tax authorities, a business group said August 12, 2026.

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The OECD spent the last decade selling its Pillar Two minimum tax on the promise it would bring in significant new revenue. Its latest figures estimate the 15% global tax raised between 79 billion and 109 billion euros ($91.2 billion to $125.8 billion) in 2024. That’s about a third of what the organization projected in 2023, a number that shrinks with every publication.

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European and allied countries pushed for optionality and reservations in a draft U.N. protocol on cross-border services income during August 10-11 negotiating sessions, expressing deep disappointment over the removal of physical presence nexus requirements and the reliance on gross-basis taxation. Meanwhile, delegates from both developed and developing jurisdictions raised concerns about potential double taxation, seeking clarity on how the protocol’s subject-to-tax rule and broader provisions will interact with existing bilateral tax treaties.

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