2026
Ireland's R&D Tax Credit Compass Outlines Potential Development
Ireland’s Department of Finance released a “compass” report evaluating the structure and future direction of its R&D tax credit regime. The review identifies potential reforms to enhance competitiveness, refine qualifying expenditure rules, and reconsider capital treatment while streamlining administration. The initiative reflects broader policy recalibration as Ireland balances fiscal cost, EU considerations, and multinational investment incentives.
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Singapore to Raise More Corporate Tax With Pillar 2 Top-Up Tax
Singapore projects increased corporate tax revenue from the fiscal year 2027 as it implements the OECD pillar 2 regime through an MNE top-up tax and a domestic top-up tax. Officials emphasized that while the 15% minimum rate will boost collections, Singapore must expand targeted incentives to remain competitive in a reshoring environment. The 2026 budget pairs minimum-tax compliance with measures such as a 40% corporate income tax rebate and enhanced internationalization and innovation incentives.
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Poland Consults on Digital Services Tax, Faces Critical Next Step
Poland is consulting on a proposed 3% digital services tax targeting large multinationals with significant global and Polish revenue thresholds. Stakeholders raised concerns about competitiveness, administrative complexity, enforceability, and possible U.S. retaliation, while the finance ministry reportedly remains cautious about alignment with international tax commitments. Inclusion in the government’s legislative agenda will determine whether the DST advances toward parliamentary debate in 2026.
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Nations Back Launch of Transfer Pricing Task Force at UN Talks
A United Nations committee will form a task force to look at why developing nations can’t access transfer pricing databases, after hearing support for the move from a large group of countries as part of negotiations for a new UN tax treaty.
Global Fund Critiques Proposed Regs on U.S. Investments by Foreign Governments
The New Zealand Superannuation Fund contends that proposed section 892 regulations depart from longstanding interpretations by reversing the presumption that debt investments are non-commercial and expanding the effective control standard. The submission argues that routine creditor protections and minority governance rights could inadvertently trigger commercial activity or tainting under the revised framework. It urges the Treasury to restore the non-commercial presumption, clarify safe harbors, and provide grandfathering relief for existing sovereign investments.
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Digital Services Taxes and the WTO
The authors argue the U.S. refusal to restore a functioning WTO appellate system amid DST disputes is a rational response to asymmetric litigation risk, not hypocrisy. They contend that any U.S. challenge to foreign DSTs could invite counterclaims targeting U.S. tax provisions such as FDII and IC-DISC as prohibited export subsidies, which are easier to attack under WTO doctrine than DSTs. The piece frames DST conflict as a structural tax-trade mismatch, in which U.S. corporate tax incentives may be more legally vulnerable than the DSTs the United States opposes.
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OECD Notes Progress on Addressing Harmful Tax Practices
The OECD’s Forum on Harmful Tax Practices released updated peer review findings under BEPS Action 5, assessing preferential regimes and substantial activity requirements. Ireland and Peru were found not to have harmful regimes, while Fiji abolished two incentive regimes, and Anguilla and the Turks and Caicos Islands were flagged for follow-up. The report reflects ongoing multilateral monitoring and pressure to align domestic regimes with substance and transparency standards.
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Tax Bill Slashes MNE Manufacturing Tax Rates, Report Says
A new Urban-Brookings Tax Policy Center report finds that international provisions in the One Big Beautiful Bill Act, including revisions to the net controlled foreign corporations tested income regime, substantially reduce effective marginal tax rates on new export-oriented investments. The analysis indicates that outbound manufacturing activity benefits disproportionately, potentially altering location decisions for U.S.-parented multinationals. The findings raise broader policy questions about competitiveness, base erosion, and the long-term trajectory of the post-TCJA international tax framework.
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PwC Warns Dutch Lawmakers of Corporate Exodus Amid Pillar 2 Deal
PwC told Dutch lawmakers that the pillar 2 “side-by-side” safe harbor could prompt multinationals to shift their headquarters, R&D, or other high-value functions out of the Netherlands, thereby threatening the corporate tax base. It urged policymakers to consider competitiveness responses, such as lowering the corporate rate, redesigning innovation box incentives to align with the substance-based safe harbor, or using Article 11 of the EU Pillar 2 directive to opt out of the domestic top-up tax. The warning reflects broader EU tensions between minimum-tax coordination and national competitiveness strategies, as pillar 2 begins to influence location decisions.
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