Int'l Tax News

The Treasury Department announced an agreement with OECD Inclusive Framework members confirming that certain U.S.-headquartered multinational groups will be exempt from key elements of the Pillar Two global minimum tax regime. The announcement reflects ongoing efforts to align the Pillar Two framework with existing U.S. tax rules, including the treatment of GILTI. Treasury emphasized that the agreement preserves U.S. taxing rights while reducing the risk of double taxation for U.S. multinationals operating abroad. The development has important implications for the future interaction between U.S. international tax law and the OECD’s global minimum tax project.

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This press release announces that the 147 members of the OECD/G20 Inclusive Framework have agreed on key elements of a package advancing the coordinated operation of the global minimum tax, which includes the side-by-side approach reflected in the Tax Notes article

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US business groups and lawmakers welcomed an agreement reached by over 140 countries at the OECD that would exempt American companies from major parts of the global minimum tax framework.

The Trump administration notched a major win for US companies, securing a commitment from international negotiators at the OECD to exempt them from key provisions of the global minimum tax.

Last year was supposed to mark the moment international trade was dismantled. President Donald Trump’s tariffs, we were told, were so unprecedented in scale and ambition that they might stop globalization in its tracks.

This article evaluates how the G7’s Pillar Two statement could affect the application of minimum tax rules to U.S.-parented multinational enterprises

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Countries at the United Nations are looking at sweeping changes to transfer pricing rules as they design a tax treaty acceptable to developing economies. But easing access to transfer pricing information could emerge as a more realistic outcome.

Summarizes Ireland’s 2026 budget tax measures, including extensions of credits and reliefs affecting individuals and businesses.

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Examines the European Union’s 2026 tax priorities, highlighting the growing role of soft law, administrative coordination, and simplification efforts alongside carbon border and minimum tax initiatives.

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Businesses will keep a close eye on negotiations at the United Nations over global tax rules, with first drafts and their economic impact studies planned to be released next year.

Five years after the Covid-19 lockdowns, there has been a significant increase in enterprises looking to enable cross-border remote work, partly due to a desire to expand into new markets but predominantly due to increased demand from individuals.

The OECD asked 26 countries to improve their facilitation of tax rulings that help tax authorities in risk assessments and counter base erosion and profit shifting concerns, according to a new report.

The Trump administration threatened retaliation against the European Union in response to efforts to tax American tech companies, singling out prominent companies, including Accenture Plc, Siemens AG and Spotify Technology SA, as possible targets for new restrictions or fees.

Nana Ama Sarfo explores how some countries are using the revenue results of their digital services taxes — whether better or worse than expected — as justifications for expanding their measures.

Alina Miyake and Lucas de Lima Carvalho explore Brazil’s signing of the OECD multilateral instrument and the implications for Brazil's tax treaties.

Vietnam’s National Assembly has amended the Tax Administration Law to require online platforms to remit taxes on behalf of parties selling goods and services over their systems.

France's Directorate General of Public Finances has published a user guide for taxpayers required to file information returns under the country’s global anti-base-erosion rules, confirming plans to open a submission platform by May 2026.

The Australian Taxation Office has released final guidance on how it will grant full or partial exemptions for public reporting of multinational enterprises' tax information on a country-by-country basis.

Mukesh Butani, Shankey Agrawal, Harsh Shukla, Pratha Khanna, and Spandana Koona examine the impact of U.S. tariffs on global trade and offer recommendations for establishing treaty standards to protect against future uncertainties.

The OECD on December 9 published its 2025 tax revenue statistics report, finding that the average tax-to-GDP ratio across member jurisdictions increased from 33.7 percent to 34.1 percent between the 2023 and 2024 financial years, with social security contributions and personal income taxes accounting for the largest shares of revenue on average in 2023 at 25.5 percent and 23.7 percent, respectively.

This third piece of a series comparing Canada and US individual and business tax rules analyzes how Canada’s Nov.4 federal budget provisions affect the comparisons of Canada’s tax rules to their US counterparts. Draft legislation (Bill C-15 issued on Nov. 18 ) reflects some of the budget proposals and the balance will be dealt with in subsequent legislation, and tax changes are generally prospective not retroactive.

A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration’s aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026.

Belgian Finance Minister Jan Jambon said the EU's evaluation of pillar 2 must account for the major political changes now underway around the world.

Michael N. Kandev examines current transfer pricing guidelines in Canada and compares them with proposed changes in the 2025 budget.

Mindy Herzfeld examines the headwinds facing the OECD pillar 2 global minimum tax project.

The Netherlands recognizes the importance of favorable treatment of substance-based nonrefundable tax credits under OECD global minimum tax rules, but restrictions are necessary to preserve pillar 2’s goals, a top Dutch tax official said.

 The following amicus curiae brief was filed with the Court of Justice of the European Union on November 19 by an international group of tax professors regarding a U.S. business lobby group’s legal challenge against Belgium’s undertaxed profits rule in American Free Enterprise Chamber of Commerce v. Ministerraad, C-519/25.

The OECD plans to soon focus on global mobility and helping tax systems adjust to remote working, Manal Corwin, director of the organization’s Center for Tax Policy and Administration, said. 

Nana Ama Sarfo discusses how the Trump administration’s efforts to combat discriminatory unilateral measures in the digital economy are extending past digital services taxes and including indirect taxes like value added taxes.

The U.K. government has confirmed it is now targeting 2027 for the implementation of OECD pillar 1 reforms that would require the rollback of digital services taxes, citing a delay in negotiations.

House Republican taxwriters revived a threat to institute retaliatory international taxes if global powers don’t show progress on the agreement to exempt American companies from some OECD global minimum tax rules by the end of 2025.

South Korea’s National Assembly has passed legislation increasing each of the country’s four corporate tax rates by 1 percentage point and establishing a tax scheme for “high-dividend companies" meant to revitalize capital markets.

Reuven S. Avi-Yonah examines the legislative history of the net controlled foreign corporation tested income and corporate alternative minimum tax regimes to determine whether pillar 2 can survive side by side with them.

It is vital that an international tax deal be promptly finalized to “provide certainty for U.S. companies and fair treatment for foreign companies who wish to invest in the United States,” House Ways and Means Tax Subcommittee Chair Mike Kelly, R-Pa., said in his opening statement at a December 3 hearing on global competitiveness.

A majority of people in Asia support tax incentives to attract multinational companies and view global tax cooperation as important, according to a newly published survey by the OECD.

 The United Kingdom will proceed with legislation to reform the country’s transfer pricing, permanent establishment, and diverted profits tax rules, while a matrix for related-party transactions will need to be significantly fleshed out through secondary legislation.

The OECD Global Forum on Transparency and Exchange of Information for Tax Purposes on December 2 published its 2025 annual report detailing the current progress on its cross-border administrative transparency initiative across 172 member jurisdictions, finding that over 32,000 information requests were sent during the 2024-2025 fiscal year and that over 70 jurisdictions are committed to implementing the cryptoasset reporting framework and sending out their first exchange requests by 2027.

House Ways and Means Committee Chair Jason Smith (R-Mo.) fired a warning shot to countries negotiating a revised global minimum tax deal at the OECD, vowing to take action if there’s no agreement to exempt US companies from the tax.

Three European countries are progressing with the implementation of global minimum tax rules, with Switzerland and the United Kingdom amending their pillar 2 laws and Montenegro consulting on draft pillar 2 legislation.

The EU could take steps to harmonize wealth and cryptoasset taxation, digitalize tax administrations, and reduce compliance burdens without infringing on member states' national tax competence, according to a new study.

Thomas Horst, Thomas Meyer, and Priyan Thurairatnam present and analyze data regarding the disproportionate effects of the 2025 tariffs on large U.S. corporations.

The global economy is weathering Donald Trump’s trade tariffs better than expected as activity gets a boost from strong investment in artificial intelligence and supportive fiscal and monetary policies, the OECD said.

A group of House Republicans is urging the Trump administration to put all options on the table, including tariffs, to pressure France to abandon its digital services tax hike.

Revenues raised by the United Kingdom's digital services tax have increased year over year as its digital economy continues to expand; applying the DST to online advertising might be next, a government review says.

The OECD is asking stakeholders for input on potential issues arising from global mobility of workers, including its impact on corporate and personal income tax.

Multinationals are seeking rule changes from Treasury allowing them to take more credits against taxes they pay abroad on their income.

The Trump administration reached a deal with the UK to allow tariff-free imports of pharmaceutical products in exchange for a significant reduction in rebates drugmakers pay to Britain’s National Health Service.

The UK government said it will amend its global minimum tax regime to reflect ongoing multilateral negotiations.

The European Parliament’s Economic and Monetary Affairs Committee called for digital, wealth, and financial transaction taxes and an excise duty on share buybacks in a recent draft opinion on new own resources.