Int'l Tax News

Examines Turkey’s reduction of its digital services tax rate and considers broader implications for digital tax policy and international coordination.

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Reviews international parliamentary efforts to address multinational tax avoidance and the growing use of protectionist tax measures, examining the Inter-Parliamentary Union’s proposed resolution and its potential role alongside existing global tax coordination initiatives led by the OECD/G20 and the U.N. Tax Committee.

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Discusses how AI-driven tax modeling and new legislation are reshaping tax administration and compliance globally.

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An Amsterdam appeals court ruled that Uber drivers can qualify as entrepreneurs rather than employees, overturning a lower court decision that would have imposed retroactive employment obligations on Uber. The ruling emphasizes individual drivers’ degree of entrepreneurship and leaves enforcement of misclassification rules largely to tax authorities.

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This article explores how technological change, regulatory uncertainty, and enforcement pressures are reshaping global transfer pricing risk heading into 2026.

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Poland says it will draft legislation for a digital services tax of up to 3% aimed at large groups, framing the measure as a competitiveness and “digital sovereignty” response to cross border platform activity that is monetized in Poland but taxed elsewhere. The proposal targets revenues from targeted advertising, multilateral platform intermediation, and monetization of user derived data, while carving out streaming content, communications and payments, and direct online sellers that are not intermediaries. The tax would apply only above both a global size threshold and a Poland revenue threshold, and would be reduced by Polish corporate income tax, which is a design choice meant to blunt double taxation and treaty friction but also raises base definition and crediting questions.  

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Despite the growing complexity of border crossings and regulatory requirements, the need for workforce mobility—and its benefits—remains as vital as ever. Organizations continue to rely on international collaboration and flexible talent exchange as key drivers of growth, innovation, and competitive advantage.

A draft protocol on dispute prevention and resolution under the U.N. tax cooperation framework would focus on resolving cross-border tax disputes between states arising under existing bilateral or multilateral tax treaties, while also exploring optional mechanisms for no-treaty situations, expanded MAP tools, coordinated APAs, and a possible U.N.-led transfer pricing task force. 

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The OECD’s long-awaited side-by-side package is a pragmatic attempt to preserve the global minimum tax architecture while accommodating the unique position of US multinationals. That pragmatism, however, comes with limits.

There is “still willingness from all jurisdictions” at the OECD to restart stalled negotiations for a global tax on digital services, but the talks will likely deviate from the framework’s current construction, according to a senior EU official.

United Nations negotiators working on a new global tax treaty plan to establish a task force to explore and identify practical options for improving countries’ access to transfer pricing information.

A global agreement to exempt US multinationals from key parts of the 15% global minimum tax is raising concerns that its rules may tie the hands of Congress to make corporate-friendly changes to the US tax code in the future.

The OECD’s new “side-by-side” agreement for Pillar Two marks a decisive shift in the global minimum tax project—and not in Canada’s favor.

The OECD’s landmark global minimum tax deal isn’t guaranteed to succeed, according to the UN official leading negotiations on a new international tax convention.

The Japanese government approved changes to its global minimum tax system to implement the OECD’s recently revised agreement.

United Nations negotiators working on new global tax rules issued a draft paper suggesting options for how and when countries can tax cross-border services that result from remote work and digitalization.

See attached the draft for the cross-border “protocol”.

The U.N. released an updated draft framework convention on international tax cooperation that would set principles for sustainable development, fair allocation of taxing rights, measures targeting high-net-worth individual avoidance/evasion, harmful tax practices, and expanded mutual administrative assistance and exchange of information, with protocols contemplated to implement specific rules.

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Simplification measures in the OECD’s new global minimum tax rules are unlikely to reduce the compliance burden for companies as they determine their tax liabilities under the new system, tax professionals said.

Multinationals asked the OECD for more clarity on complex questions around how corporations should be taxed in relation to remote work and a safe harbor for short-term cross-border working.

Here is the OECD consultation document on remote work, along with comments on it.

Trade frictions across the European Union are more onerous than the highest tariff US President Donald Trump threatened to slap on the bloc last year, according to research by the European Central Bank.

Companies need additional guidance on the impacts of remote work on corporate taxes and the creation of taxable permanent establishments, practitioners told the OECD in comments as part of the group’s global workforce mobility project.

Developing countries will want to adopt the global minimum tax because they will collect revenue, and further work is being done to make the levy more administrable, a top OECD official said.

Supporters of the OECD’s new Pillar Two “side-by-side” agreement—which carves the US out of the global minimum tax—claim the deal protects US tax sovereignty and preserves Congress’ authority over domestic tax law.

The European Commission published changes to the bloc’s minimum tax law in its official journal, putting into legal effect the revised the agreement reached by countries at the OECD last week.

Singapore should use an upcoming budget to issue new guidance on the global minimum tax and expand an investment credit launched in the tax’s wake, Deloitte said.

Examines a new OECD initiative aimed at ensuring mutual agreement procedures remain available for adjustments that are substantively transfer pricing–related but not formally characterized as such.

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Discusses the evolving landscape of tax transparency initiatives heading into 2026, including developments in information exchange standards, reporting obligations, and global forums’ efforts to enhance cross-border cooperation and combat tax evasion

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The European Commission issued guidelines on how it addresses situations in which foreign subsidies, such as tax credits and other tax relief, may distort competition.

Digital services taxes will occupy a prominent place on the global tax agenda for 2026 because some EU nations will insist on their use and because a growing number of nations are realizing that DSTs may not be worth having—especially when an easy alternative already exists.

US President Donald Trump could find out as soon as Jan. 9 whether the Supreme Court will strike down a key portion of his tariffs campaign. The court is considering whether Trump can use an emergency law that had previously never been wielded to impose import taxes, and its decision could be included in an upcoming opinions release on unspecified cases.

It’s time to step back and assess prior work undertaken at the OECD to tax the digital economy, a top US Treasury Department official said.

The Trump administration ordered the US to withdraw from various international organizations, including a United Nations body responsible for developing tools to aid countries in international tax cooperation.

OECD member countries may consider resuming talks on a multilateral global tax deal on digital services at a meeting in April, a top official said.

Reports that the Netherlands plans to introduce legislation implementing the OECD side-by-side package, with stakeholder consultations expected before summer.

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Examines political and policy challenges facing countries engaged in U.N.-led tax negotiations as deadlines approach.

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Transfer pricing, which is how companies price transactions between affiliates, underwent colossal changes in the US over the past year, and the new year promises to be at least as tumultuous.

The UK will amend its global minimum tax law to apply recent changes to the OECD-led framework from January 2026, the country’s tax minister said.

Discusses proposals from Dutch tax advisers on incorporating the EU’s Unshell initiative into DAC6 reporting obligations through the creation of a new disclosure hallmark.

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Mindy Herzfeld reviews major international tax developments from 2025,  including disruptions to the OECD’s two-pillar project, evolving tariff policy, and legislative, regulatory, and judicial uncertainty, and assesses what these trends suggest for the international tax agenda in 2026.

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Examines the European Commission’s plan to recalibrate its tax agenda in 2026 by prioritizing narrower, targeted initiatives over broad, comprehensive reforms.

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Covers a planned legal challenge to Belgian legislation authorizing tax authorities to use artificial intelligence to mine financial data, focusing on privacy and proportionality concerns.

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Examines unresolved conceptual and practical issues surrounding the treatment of goodwill in transfer pricing analyses and disputes

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