2026

Majdowski and Smoleń examine how pillar 2’s GloBE regime links transfer pricing outcomes directly to jurisdictional effective tax rate and top-up tax calculations, heightening the consequences of pricing design. They highlight Article 3.2.3 of the model rules as a symmetry mechanism addressing unilateral adjustments, APAs, and post-filing true-ups, and assess how misstatements may trigger pillar 2 exposure under jurisdictional blending and transitional safe harbors. The authors argue that pillar 2 elevates transfer pricing from a bilateral controversy issue to a core component of the global minimum tax compliance strategy.

Wolski and Yen assess potential legislative refinements following enactment of the One Big Beautiful Bill Act, focusing on structural tensions in the NCTI regime and the base erosion and anti-abuse tax. They propose changes to foreign tax credit basket design, haircut limitations, carryforwards, and branch-CFC alignment to mitigate double taxation and improve administrability. The article frames international tax reform as ongoing, with competitiveness and systemic coherence likely to shape the next phase of congressional action.

Commenters cautioned that proposed section 892 regulations expanding the definition of “effective control” could disrupt established sovereign investment structures. They argue that broadening control to include certain managerial and veto rights may narrow the exemption for qualified U.S. investments and create uncertainty for minority sovereign investors. The debate highlights the tension between anti-avoidance safeguards and maintaining the United States’ attractiveness to inbound sovereign capital.

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.

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.

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.

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.