Fresh Ideas Emerge for New EU Budget Levies

The European Parliament is considering new EU own resources that would tax online gambling, speculative real estate investment, and large companies through a turnover-based CORE contribution. The proposals expose significant legal and institutional constraints, including unanimity requirements, subsidiarity limits, especially for gambling, and unresolved questions about where digitally delivered activity should be taxed. Academic analysis warned that CORE could lead to multiple counting within corporate groups and impose tax liabilities that are disconnected from profitability, raising concerns about neutrality, legal characterization, and enforceability.  

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Taxation and Deglobalization

  • By Reuven S. Avi-Yonah

This article examines how the shift away from globalization may reshape taxation and tax policy. It analyzes the relationship among globalization, tax competition, capital mobility, and the financing of social safety nets, arguing that deglobalization may give governments greater room to raise revenue without the same degree of tax-base erosion associated with international tax competition. The article also considers the potential revenue implications of higher tariffs and reduced tax evasion.

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Challenges of Taxing Business Profits Arising from Digital Transactions in Rwandan Law: A Critical Analysis of the Legal Framework and the Way Forward

  • By Jonas Niyitegeka

This paper examines the structural challenges facing Rwanda in taxing business profits arising from digital transactions. It analyzes gaps in the country’s digital tax framework, including limitations in permanent establishment and digital nexus rules, as well as jurisdictional and enforcement challenges. The paper also considers international responses to digitalization, including the OECD/G20 Pillar One and Pillar Two framework, and recommends reforms addressing digital presence, bilateral tax treaties, and regional coordination within the East African Community.

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MNE Responses to the Global Minimum Tax

  • By Lucía Contreras
  • By Felix Hugger
  • By Tom Zawisza

This OECD Taxation Working Paper provides an early empirical, ex post assessment of how multinational enterprises responded to the introduction of the Global Minimum Tax. Using the EUR 750 million revenue threshold and firm-level data, it examines the reform’s effects on effective tax rates, investment, and employment, as well as whether MNEs adjusted their behavior in anticipation of implementation. The paper also uses its estimated effects on effective tax rates to assess the potential revenue raised by the Global Minimum Tax in its first year.

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Measuring Location-Specific Rents

  • By David Elkins

This article examines location-specific rents as a basis for allocating taxing rights among sovereign states and addresses the practical challenge of measuring such rents. It argues that tax competition can help quantify the income international firms derive specifically from operating in a particular jurisdiction. The analysis has implications for inter-nation equity and the allocation of source-country taxing rights in international taxation.

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From "Reporting" to "Rule-of-Law": Digital Governance as a Defensive Shield Against Administrative Discretion in Emerging Markets

  • By Zhanqi Wang

This paper examines tax compliance challenges faced by multinational enterprises operating in emerging markets, focusing on administrative discretion, regulatory ambiguity, and aggressive tax audits. Using a mining project in Sierra Leone as a case study, it analyzes how a multinational enterprise responded to a contested tax assessment and argues for digital compliance systems as a means of institutionalizing tax controls and reducing exposure to discretionary enforcement. The paper highlights the role of internal tax governance and digitalization in managing tax risk in weak institutional environments.

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Jane Street Capital's Indian Tax Battle Begins

  • By Poonam Khaira Sidhu
This article examines the developing Indian tax controversy involving Jane Street Capital as the Indian Revenue builds its case around purpose, control, and substance. It focuses on treaty entitlement rules in India and other jurisdictions in the digitalized post-BEPS economy.

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The Paradox of Reporting Without Visibility: How DAC8 And CARF Expose the Limits of Transparency-Based Taxation in Crypto-Assets

  • By Johann Thevot
This paper examines whether DAC8 and the OECD Crypto-Asset Reporting Framework provide a coherent system for the international taxation of crypto-assets. It focuses on the limits of intermediary-based reporting for decentralized finance and self-custody, as well as the cross-border tax mismatches that arise when jurisdictions classify staking, mining, airdrops, NFTs, stablecoins, and decentralized-finance income differently.

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U.S. Tax Reform and International Trade

  • By Travis Chow
  • By Xuanpu Lin
  • By Edward L. Maydew
  • By Guoman She
This paper examines how the 2017 U.S. tax reform’s international tax provisions affected U.S. firms’ cross-border trade in physical goods. It uses firm-level shipping-container data to show changes in exports, imports, and intersegment sales across geographic segments after the reform.

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Tax Inspectors Without Borders Annual Report 2026

  • By OECD - United Nations Development Programme

This report reviews the work of the Tax Inspectors Without Borders initiative, a joint OECD/UNDP program supporting developing jurisdictions in tax audits, enforcement, and international tax administration. It highlights how capacity-building programs are being used to strengthen audit outcomes, address cross-border tax issues, and combat illicit financial flows through practical assistance to tax authorities.

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30 Years of Research on Income Shifting—Review and Looking Ahead

  • By Lisa De Simone
  • By Kenneth J. Klassen

This paper provides a structured survey of three decades of empirical research on tax-motivated income shifting by multinational corporations. It organizes the literature around the mechanisms, determinants, consequences, and estimated magnitudes of income shifting, and identifies areas where future research could improve measurement methods and expand analysis of multinational tax planning behavior.

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