Fresh Ideas Emerge for New EU Budget Levies

This paper examines how Mexican labor, tax and financial law would apply to employer-provided AI token budgets and proposes a four-level framework based primarily on how freely employees may use the tokens. Tokens restricted to work purposes would constitute work tools rather than salary, while tokens available for personal use would constitute in-kind benefits forming part of salary and taxable income. Transferable tokens usable as payment could potentially qualify as virtual assets under Mexico’s Fintech Law if they are not denominated in currency, although the paper concludes that AI tokens cannot themselves constitute money or replace wages required to be paid in legal tender.

To read the full article, click here.

This General Report examines the function of corporate tax residence across domestic income tax systems and tax treaties, drawing on branch reports prepared for the International Fiscal Association’s 2025 Lisbon Congress. It identifies substantial variation in domestic approaches involving incorporation, governance and other residence criteria, alongside a trend toward expanding the scope of corporate residence. At the treaty level, the report finds that most treaties still use place of effective management as a tie-breaker but identifies a progressive shift toward mutual agreement procedures, which the author argues creates uncertainty because corporate residence often determines exposure to worldwide taxation.

To read the full article, click here.

This article examines the 15 percent minimum effective tax rate and controlled foreign company rules introduced by the Nigeria Tax Act 2025. It analyzes the Act’s treatment of certain undistributed profits of controlled foreign companies and the imposition of top-up tax where relevant foreign subsidiaries are taxed below the prescribed minimum ETR, comparing these rules with income-inclusion concepts and the OECD/G20 Pillar Two framework. The authors emphasize that, although Nigeria’s regime resembles aspects of the GloBE Rules, Nigeria remains outside the Inclusive Framework’s Two-Pillar Solution and has adopted a distinct domestic regime.

To read the full article, click here.

This work examines changes in international corporate taxation from 2008 to 2021, culminating in the October 2021 agreement establishing a two-pillar framework and a 15 percent country-by-country minimum effective corporate tax rate. It analyzes how the 2008 financial crisis and COVID-19 pandemic contributed to reform through G20 and OECD initiatives and examines the role of the Transnational Tax Policy Community in shaping the international tax agenda. The author also argues that domestic politics significantly affect implementation and enforcement, highlighting the continuing tension between multilateral tax cooperation and national sovereignty.

To read the full article, click here.

This paper examines Article 12AA of the 2025 UN Model Tax Convention, which grants source-based taxing rights over imported cross-border services regardless of the service provider’s physical presence. It argues that the provision can help developing countries address base erosion and simplify tax collection by complementing traditional physical-nexus rules and reducing the need for complex service classifications. The paper also considers the challenge of translating the new provision into practical tax administration.

To read the full article, click here.

This paper examines how six types of tax incentives interact with Pillar Two and the Qualified Domestic Minimum Top-up Tax by simulating their post-QDMTT effective tax rates using a common GloBE Income base. It finds that income-based exemptions and non-qualified tax credits are compressed toward the 15% minimum rate, while qualified refundable tax credits generally preserve more incentive value because they are treated as GloBE Income rather than reductions of Covered Taxes. Accelerated depreciation produces an intermediate result because its effect is primarily one of timing rather than a permanent tax difference.

To read the full article, click here.

This article examines whether the proposed global minimum corporate tax can adequately address corporate tax arbitrage and argues that deficiencies in international tax dispute resolution may complicate its implementation. It calls for strengthening the mutual agreement procedure and examines the potential conflict between national tax sovereignty and investor protections under investor-state dispute settlement, particularly as minimum-tax rules are implemented through domestic legislation. The author argues that reconciling these regimes is important to addressing investment disputes that could challenge the implementation of BEPS 2.0.

To read the full article, click here.

This article examines the effectively connected income rules governing foreign persons engaged in a U.S. trade or business and identifies two features that can distort the determination of U.S. business income. The authors argue that the U.S.-office-or-other-fixed-place-of-business requirement can underinclude income generated by U.S. business activities, while the residual force-of-attraction rule can overinclude income. They propose eliminating the USFPB requirement for determining the ECI status and source of certain income, as well as the residual force-of-attraction rule, to more accurately capture income generated by foreign persons’ U.S. business activities.

To read the full article, click here.

This paper examines why governments concede taxing rights in bilateral tax treaties. Min constructs a global dataset coding 20 provisions in more than 4,000 bilateral tax treaties and analyzes how political institutions and ideology affect host-country taxing rights, including rights over income and payments generated exclusively by foreign firms. The paper finds that democracies across the ideological spectrum, as well as left-wing nondemocracies, grant lower host taxing rights on these foreign-firm tax bases, but not on other bases such as foreign individuals’ income or domestic firms’ outgoing payments.

To read the full article, click here.

This article examines the characterization of cross-border software payments as royalties, focusing on arrangements in which royalty elements may be embedded in broader software or service payments and thereby raise withholding-tax issues. It compares the treatment of royalties under the Commentaries to the OECD and UN Model Tax Conventions, recent judicial decisions, and the Australian Taxation Office’s TR 2024/D1. Azzi argues that TR 2024/D1 departs from international norms and creates uncertainty that may increase the incidence and duration of treaty-based disputes over the characterization of software payments.

Citation: Bulletin for International Taxation, 2026 (Volume 80), No. 9/10 (Next issue) https://doi.org/10.59403/acm9qw

To read the full article, click here.