Int'l Tax News

The OECD’s framework for overhauling the way multinationals are taxed is “dead,” the chair of Ireland’s state-sponsored foreign-direct investment body said.

Nana Ama Sarfo outlines a discussion at the recent IFA Congress in Lisbon about the need for standardization in determining the place of effective management in this era of cross-border remote work.

Much uncertainty remains in worldwide tax with less than a year to go before the first pillar 2 global anti-base-erosion information returns must be filed, a panel said.

Countries are still divided on a number of issues as they renegotiate the global minimum tax agreement, according to Tim Power, chair of the Committee on Fiscal Affairs at the OECD.

EU countries will be able to selectively apply changes to the minimum tax law before revising their domestic law, according to a senior European Commission official.

The European Commission's 2026 work program announced the withdrawal of several tax proposals, including those that would have addressed the debt-equity bias, negotiated a financial transaction tax, and harmonized transfer pricing rules.

Advocacy group BusinessEurope called on the European Commission to show “ambitious leadership” to secure global consensus on pillar 2, extend its safe harbors, and “bring genuine” simplification and investment-friendly tax rules.

The United Nations approved a plan to develop guidance making it easier for developing countries to tax companies without a physical presence within their borders.

The EU should revisit its minimum tax law “to ensure it remains a reasonable and proportionate way forward” for European businesses, said BusinessEurope, a trade association representing Europe’s industry.

Kimberly S. Blanchard responds to a recent letter by Patrick Driessen to clarify her perspective on U.S. foreign tax credits and their relationship to international tax policy.

Mindy Herzfeld considers the One Big Beautiful Bill Act’s changes to key international tax provisions in the Tax Cuts and Jobs Act, highlights areas where pre-TCJA rules no longer make sense, and proposes changes to reduce the rules’ complexity and lower compliance costs to U.S. taxpayers.

Reuven S. Avi-Yonah examines the United States’ reticence to embrace the VAT and argues that its regressivity can be negated.

Mindy Herzfeld considers the One Big Beautiful Bill Act’s changes to key international tax provisions in the Tax Cuts and Jobs Act, highlights areas where pre-TCJA rules no longer make sense, and proposes changes to reduce the rules’ complexity and lower compliance costs to U.S. taxpayers.

G20 members have pledged to advance multilateral talks on an approach to address outstanding concerns about the OECD global minimum tax framework but said its delivery will need to meet certain requirements.

While the EU still generally favors a global agreement on digital taxation, Italian and Spanish officials appeared open to the suggestion of a permanent digital establishment at a recent interparliamentary meeting of the European Parliament.

The OECD base erosion and profit-shifting project has reduced tax avoidance over the past 10 years, but countries will further its progress by simplifying compliance burdens and supporting global minimum taxation, the organization said.

Robert Goulder comments on the Trump administration’s shifting legal basis for tariff authorization.

The United Nations committee for helping developing nations boost tax revenue will decide next week whether wealth taxes, critical minerals, or transfer pricing will figure among the priorities in its new four-year term.

The Group of 20 nations agreed to continue working towards an agreement on the global minimum tax.

Reuven S. Avi-Yonah explores the status of transfer pricing and suggests the United States move to a single-factor formula, with sales of a multinational enterprise into the United States taxed by the United States.

Hafiz Choudhury and Peter Hann examine the legislative history of the U.N. framework convention on international tax cooperation and identify potential obstacles to its implementation.

OECD Secretary-General Mathias Cormann has submitted a report to G20 finance ministers and central bank governors on tax developments in the implementation of pillar 2; tax knowledge inequality and growth; reforms to support global mobility; approaches to environmental taxation; support for developing countries; and transparency.

EU officials affirmed the OECD’s framework to reallocate corporate profits as the best chance of enforcing an effective tax on digital services.

The US budget deficit declined slightly for the 2025 fiscal year as tariff revenue hit a record high, though the pace of borrowing remains historically elevated at a time of economic expansion and financial stability.

Countries in the EU and beyond are continuing to implement pillar 2 global minimum tax rules through guidance and draft reforms and regulations, with one jurisdiction proposing to introduce the rules for the first time.

The OECD aims to reach an agreement to re-write major parts of the global minimum tax by the end of the year, its Secretary-General told the G20 Finance Ministers and Central Bank Governors in a report.

Poland intends to finalize plans for a digital services tax by the end of the year, according to Deputy Prime Minister Krzysztof Gawkowski.

Isabella Barreto compares digital services taxes with traditional sin taxes, arguing that DSTs' association with market dominance, externalities, and social harm contains a strong similarity with the logic and moral undertones of sin taxes.

Patrick Driessen responds to the idea that the OECD’s pillar 2 tax test can be fulfilled if income sourced in a particular nation is taxed “somewhere” at 15 percent.

The world’s shipping regulator is on the verge of green-lighting a global charge on the industry’s emissions, something that has prompted the Trump administration to threaten tariffs in response.

Nana Ama Sarfo discusses the historical context for a proposal floated at the U.N. for a public transfer pricing comparables database.

Carrie Brandon Elliot reviews the link between tariffs and transfer prices in section 1059A and accompanying regs.

Reuven S. Avi-Yonah examines the arguments for and against the U.S. government’s revenue collection deal with Nvidia and AMD and its investment in Intel.

Treasury and the IRS have a large assortment of guidance teed up this year to implement the One Big Beautiful Bill Act’s international tax provisions, tax practitioners told Tax Notes.

Tim Messner examines the German royalty barrier rule’s problems and its likelihood of being replaced.

As governments deploy tariffs to advance their positions in ongoing trade disputes, multinational entities are confronting a new layer of tax complexity. The United States’ 2025 reciprocal tariff regime has forced companies to revisit not just supply chains but also how they set transfer prices across borders. This article examines the collision of tariffs and transfer pricing, modeling real-world scenarios and exploring strategies to mitigate risks while staying tax compliant.

The European Commission is seeking authorization from EU member states to negotiate the U.N.'s second protocol on tax dispute resolution on behalf of the bloc, arguing that the talks include matters within the EU’s competence.

Patrick Driessen argues that U.S. tax changes coupled with accommodations by the OECD in pillar 2 will lead to very low global corporate income tax collections and that U.S. and global interests would be better served by a strong pillar 2 that treats the United States like any other nation.

 For the New York University School of Law's 27th annual David R. Tillinghast Lecture on International Taxation, Ruth Mason examines the European Union’s state aid law and enforcement through a review of the Apple and other major state aid cases pursued by the European Commission.

Lee A. Sheppard examines the changes the One Big Beautiful Bill Act made to global intangible low-taxed income and foreign-derived intangible income rules and how those changes interact with the OECD’s BEPS 2.0 project.

Negotiations on finalizing pillar 1 profit allocation reforms that would abolish digital services taxes will continue once pillar 2 global minimum tax issues are settled, but the DST debate isn’t likely to disappear anytime soon.

Doron Narotzki examines the difficulties with applying the EU’s digital services tax to U.S. companies and argues for the adoption of a VAT as a better option for both parties.

An effort by OECD countries to revise the 15% global minimum tax to appease US President Donald Trump is complicating some mergers and acquisitions. Tax professionals caution that the revision, which would exempt US companies from major parts of the tax in an effort to mitigate Trump’s tariff threats, would also give the US a big advantage in M&A deals. In a June arrangement, the US and the other Group of Seven rich nations agreed to work on a “side-by-side” system so that the US’s rules on taxing foreign-earned income wouldn’t conflict with the global minimum tax rules. Nearly 30 nations raised concerns about the prospective deal.

International negotiations on the allocation of taxing rights will resume after outstanding issues regarding the global minimum tax are resolved, an OECD official said Friday.

Government decisions to impose digital services taxes on tech companies have been prompted in part by a lack of progress in global negotiations at the OECD, practitioners, academics and tax authority officials said.

US multinational companies are telling Congress members and the Trump administration that negotiations at the OECD to rewrite major parts of the global minimum tax framework are going too slow.

The so-called side-by-side system for exempting U.S.-parented multinational enterprise groups from some global minimum tax rules will require clear safeguards, a top European Commission official said.

Mindy Herzfeld examines the connections between the OECD’s pillar 2 framework and the European Commission’s application of the state aid doctrine to tax.

The OECD is working to resolve issues surrounding the global minimum tax by the end of the year.