2026

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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