Int'l Tax News

What was once too much of a nuisance for the US to regulate became too big of an economic force to ignore any longer.

As President Donald Trump’s tariffs make waves in the world economy, multinational companies are mulling what it could mean for their intangible assets like intellectual property and brand recognition.

Expansion of Canada’s power to gather tax information, as the government is proposing, would open companies and individuals to excessive penalties, more government mistakes, and expensive disputes, tax professionals say.

French President Emmanuel Macron vowed a strong response if any country takes measures that undermine Europe’s digital sovereignty.

Italy is preparing to repeal its digital services tax in the 2026 budget law, according to Finance Ministry sources, after the United States renewed threats to impose tariffs in response to unilateral levies on technology companies.

Reuven S. Avi-Yonah explores the possible outcome if the OECD were to recognize the U.S. global intangible low-taxed income tax as a legitimate pillar 2 income inclusion rule.

Robert Goulder examines the (few) pros and (many) cons of taxing exports.

President Donald Trump threatened to inflict “substantial” tariffs on countries that impose digital taxes just days after Meta Platforms Inc. Chief Executive Officer Mark Zuckerberg raised concerns about the levies during a White House meeting.

Countries that have imposed digital taxes on tech giants such as Amazon.com Inc. and Meta Platforms Inc. are again under threat of retaliatory tariffs from President Donald Trump, forcing them to decide whether to resist or give in to his demands.

The Mexican government plans to increase tariffs on China as part of its 2026 budget proposal next month, protecting the nation’s businesses from cheap imports and satisfying a longstanding demand of US President Donald Trump.

The European Commission denied targeting American companies and defended the EU’s right to regulate businesses within its borders following President Trump’s threats to impose substantial additional tariffs on countries that regulate big tech or impose digital services taxes.

House and Senate leaders will have to reach a deal on funding for the IRS, OECD, and the Justice Department’s plan to reorganize the Tax Division during the upcoming government funding process.

The EU Council’s Danish presidency wants the European Commission to explain how international tax developments could affect incentives to support the Clean Industrial Deal.

Anthony Stobart, Stefano Grilli, Hendrik Breimann, Irene Reoyo, Alice de Massiac, Kristina Adamson, and Shawn Porter summarize the qualified domestic minimum top-up tax rules in Canada, France, Germany, Italy, Spain, and the United Kingdom, providing examples of typical mergers and acquisitions transactions to illustrate their application.

India’s Prime Minister Narendra Modi is seeking to overhaul the country’s complex goods and services tax, in an attempt to boost domestic spending and cushion the economic blow of US tariffs.

The European Union hit back at US President Donald Trump’s claims that digital regulations abroad are unfair, a day after he threatened to impose tariffs and other penalties on countries that tax online services ranging from social media to e-commerce.

Australian Treasurer Jim Chalmers commended a report released by the country’s Productivity Commission that recommends cutting the corporate tax rate and imposing a new tax on cash flow to spur investment and growth.

Reuven S. Avi-Yonah, Jeffery M. Kadet, and Karen Sam refute certain criticism of the proposed cloud services sourcing rules released in January, and they suggest important amendments for Treasury and the IRS to consider in implementing the final regulation.

Craig A. Hillier and Yulia Kirillova review the status of pillar 2 in light of U.S. opposition and they suggest ways to adjust the structure to accommodate the concerns of the United States and other nations while maintaining some of its benefits.

More than two dozen countries criticized a system that would exempt American multinational companies from key parts of the global minimum tax, saying it would risk undermining the tax’s effectiveness, put non-US companies at a disadvantage, and challenge their own tax sovereignty.

US President Donald Trump threatened to impose fresh tariffs and export restrictions on advanced technology and semiconductors in retaliation against other nations’ digital services taxes that hit American technology companies.

Mindy Herzfeld argues that despite the Trump administration’s strong stance against foreign discriminatory taxes, it hasn't taken serious action against them, and says that the administration’s recent deal allowing manufacturers to export AI chips to China closely resembles the types of taxes it disapproves of from other countries.

U.N. countries have very different — and sometimes oppositional — approaches to allocating taxing rights in a digitalized economy, which could complicate negotiations around cross-border services taxation, according to a recent report.

The International Centre for Tax and Development on August 7 issued a policy brief regarding the trade-offs in the U.N. negotiations for protocol 1 to the framework convention on international tax cooperation, finding that protocol 1 needs to address ongoing cross-border taxation issues as digitalization rises; that tax policymaking must be intentional; and that the United States' exit from OECD negotiations limits the potential of a comprehensive international tax standard.

As data centers become a crucial part of global digital infrastructure, revenue authorities worldwide are increasing scrutiny of how such operations may be taxed.

Building a better tax system in Australia is one of the 10 longer-term reform priorities announced by Treasurer Jim Chalmers following a highly anticipated productivity summit with key stakeholders.

Robert Goulder comments on the unexpectedly high U.S. tariffs imposed on Swiss imports.

The OECD has proposed a range of tweaks to the global minimum tax agreement in a bid to quell US concerns about how the regime affects American companies.

Since January 2025, the Trump Administration has raised tariffs on US imports to their highest average levels in recent history, from a universal 10% tariff on virtually all goods imported into the US to a threatened 145% on goods imported from China and varying levels of “reciprocal” tariffs on dozens of additional countries. These tariffs include 25% tariffs on products deemed noncompliant by the administration with the US-Mexico-Canada Agreement (USMCA) update to the North American Free Trade Agreement and 25% tariffs on steel, aluminum, and auto-related products. Other planned tariffs include pharmaceuticals, copper and copper derivatives, semiconductors, and timber and lumber. Further, the US faces retaliatory tariffs from several countries and the European Union.

Treasury and the IRS have decided to withdraw the rules applying disregarded payment losses after concerns about statutory authority led to rounds of delays and additional carveouts.

The U.N. tax committee is looking for input on which tax policy issues it should focus on during its next five-year term.

The One Big Beautiful Bill Act’s suite of international tax reforms is likely to spur a surge in tax insurance activity as companies model out the new provisions and stake out uncertain new positions, insurers say.

A Slovakian minister said he intends to present a proposal to the country’s coalition government to impose a tax on large multinational companies providing digital services in Slovakia.

Daniel N. Shaviro compares the broad effect of digital services taxes and the OECD’s pillar 1, asking whether the emergence of the former in lieu of the latter is an unforeseen benefit to the United States.

Several country representatives have expressed support for the creation of a cooperative transfer pricing comparables database under a key protocol to the U.N. framework tax convention, but others warned the task wouldn’t be easy.

The Brazilian government has proposed legislation, including tax breaks, to help exporters who will be affected by the Trump administration's recently announced 50 percent tariff on a wide range of products.

 Deductions for related-party activities carried out by multinational entities subject to Romanian tax could face limitations as part of a proposal that would abolish the country’s alternative minimum turnover tax on large companies.

Multinational companies could be subject to a tax of up to 7.5 percent on digital services provided in Poland if the parliament accepts the recommendations in a think tank’s study commissioned by the government.

The Trump administration's unusual export tax-like arrangement with Nvidia Corp. and Advanced Micro Devices Inc. could be the first of many such deals, according to Treasury Secretary Scott Bessent.

U.N. delegates expressed support for a fast-track process similar to the OECD multilateral instrument to quickly implement the provisions of the protocol to the U.N. framework tax convention on the taxation of cross-border services income.

Recent global tax changes show us heading down a path towards “tax warfare”. For the past decade, the Inclusive Framework at the OECD has been attempting to extend the taxing jurisdiction of “market countries” over large multinationals that are able to access consumers in those market countries without triggering taxing jurisdiction under traditional international tax rules. Some market countries have grown impatient and have unilaterally adopted DSTs. Recently, the Trump administration has threatened, imposed, deferred and re-imposed the highest tariffs in a hundred years on goods imported into the US, sometimes justifying these heightened tariffs as “reciprocal” tariffs to fix trade imbalances. In response, other countries are establishing or considering retaliatory tariffs and considering additional DSTs.

New nexus criteria such as significant economic presence should be explored as part of the design of the U.N. tax convention’s early protocol on the taxation of cross-border services income, according to some U.N. delegates.

President Donald Trump’s bid to rewrite the global order via a raft of new US tariffs is likely to leave the world economy smaller than it would have been otherwise and inject new tensions into America’s relationships with allies and rivals alike. There are even emerging signs of damage from the levies to the US economy.

Leopoldo Parada explores the use of digital services taxes to tax the digital sector and argues that in the EU, VAT would be a better tool.

Representatives from major trade unions across the world see an opportunity at the U.N. to push leaders from EU countries to consider the unitary taxation of multinational groups to redistribute resources to public services.

Congress had many big businesses sweating when it contemplated lowering the 3 percent base erosion percentage threshold to 2 percent in the Senate’s first version of the One Big Beautiful Bill Act.

Mindy Herzfeld examines the taxation of income from music streaming and digital album downloads, including the application of the cloud sourcing regs, the creditability of foreign taxes on digital income, and the potential benefits from the foreign-derived deduction-eligible income deduction.

Forvis Mazars practitioners explore the mechanics and interaction of tariffs and transfer pricing.

The announcement that Canada would rescind its digital services tax a day before initial tax returns and payments were due leaves open questions for taxpayers who would have been subject to that tax, including the availability of refunds for any taxpayers who may have already paid, as well as about the future course of Canadian tax policy.

Nana Ama Sarfo discusses stakeholder responses to the first workstream of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation.