Int'l Tax News

The US tariffs threatened, imposed, deferred, and changed throughout 2025 have created uncertainty for transfer pricing compliance. As multinational enterprises that import affected goods from related companies strive to navigate the changing landscape on material, new tariffs, they face increased costs, affecting not only their profitability but also their transfer pricing compliance. MNEs may be required to lower the transfer price paid to related companies for imported goods to remain within the arm’s length profitability ranges expected by the IRS.

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.

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.

The OECD on November 25 published its 2025 corporate tax statistics report that includes information on corporate tax rates, incentives, and base erosion and profit-shifting practices, finding that statutory corporate income tax rates remained stable between 2021 and 2025 and that BEPS activity has been reduced in investment hubs as a potential result from 2022 country-by-country reporting data being affected by the COVID-19 pandemic.

The misalignment between where the world’s largest companies report their profits and where they generate revenue continues to exist, but it may be decreasing in recent years, according to new a report.

G20 leaders concluded their summit by pledging to quickly reach agreement on a U.S. proposal to exempt American companies from some OECD global minimum tax rules — despite President Trump’s absence from the event.

Claudio Cipollini examines the United States’ paradoxical response to digital services taxes: By obstructing the WTO appellate body, it has removed the international institution best positioned to challenge DSTs.

G20 leaders issued a declaration following their November 22-23 summit in South Africa, emphasizing their commitment to addressing ongoing concerns with the global minimum tax standard under the OECD's two-pillar global tax reform solution; promoting fairness with substance-based tax incentives; and stabilizing international tax systems amid growing digitalization efforts.

The OECD on November 22 published the secretary-general's report to the G20 leaders regarding key tax developments and priorities, including the progress made on implementing the global minimum tax and the base erosion and profit-shifting package; intentions moving forward with work addressing tax inequality; and tax transparency alongside other capacity-building efforts.

Companies operating in Africa are feeling the impact of the 15% global minimum tax rules that have been adopted by several African countries, including South Africa, Nigeria, Kenya, Mauritius, as well as those adopted in multinational enterprise headquarters locations in Europe, Asia and elsewhere.

Negotiations on a carveout for U.S. companies from OECD global minimum tax rules have led to a renewed focus on ways to simplify those rules for companies that remain in their scope, an OECD official said.

Reopening the EU’s pillar 2 directive could leave it permanently open, the European Commission’s top tax official warned.

Allowing the U.S. global intangible low-taxed income rules to exist side by side with the OECD’s pillar 2 rules risks creating massive complexity and placing EU groups at a competitive disadvantage, executives from Italy’s largest multinationals said.

 Italian officials said the government will not repeal its digital services tax and urged renewed OECD talks on digital taxation and the coexistence of pillar 2 with the U.S. global intangible low-taxed income regime.

The Group of 20 leaders committed to addressing concerns about the global minimum tax while ensuring that a solution will be fair to all countries.

More than 300 preferential tax regimes that encourage companies to shift their profits and avoid paying tax have been amended or abolished, according to an OECD report released.

A top OECD official said that rewriting the global minimum tax to meet the Trump administration’s demands to exempt American companies isn’t preferable, but acknowledged that the US is seeking changes rather than dismantling the tax.

A proposed side-by-side approach to enforcing a global minimum tax will hurt European competitiveness and threatens ambitions for a global level playing field, tax heads for Italian multinationals said.

The Forum on Tax Administration is working on developing compliance and risk review frameworks to facilitate the effective implementation of the OECD global minimum tax rules and reduce taxpayer burdens.

The Singaporean tax authority will implement the optional amount B simplified and streamlined approach for pricing baseline marketing and distribution transactions on a trial basis before deciding whether to make it permanent.

The EU’s highest court should dismiss a U.S. business lobby group’s legal challenge against Belgium’s undertaxed profits rule because the measure can’t harm the applicants, several law professors said in an amicus curiae brief.

To read the Brief go here https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5769685

Multinationals are increasingly becoming embroiled in disputes with tax authorities around the world and spending less time on planning and strategy amid growing trade and economic concerns.

The Congressional Budget Office slashed its estimate of longer-term US fiscal savings from President Donald Trump’s tariff hikes by $1 trillion, in a move that may deepen concerns about American borrowing needs.

The 2025 update to the OECD model tax convention clarifies when a home office qualifies as a “place of business” and lists options for dispute resolution prevention.

Canada’s Department of Finance has tabled new budget legislation that would officially repeal the country’s digital services tax and implement a slew of tax credits and other incentives for businesses.

The OECD published its 2025 update to the model tax convention on income and capital, which includes changes and clarifications to provisions regarding the role of competent authorities within dispute resolution matters and tax treaty scopes; home working conditions as permanent establishments for tax purposes; the income tax treatment of natural resource extractions; transfer pricing and financial transactions; optional decision-making in dispute resolution mechanisms; and the use of information obtained through automatic exchange agreements.

Many countries expressed concern about a proposal that the United Nations set up and run a database to help developing nations have access to transfer pricing information under a new global tax treaty.

Don’t go making plans just yet to spend the $2,000 tariff “dividend” rebates President Donald Trump has proposed for millions of Americans.

The OECD has proposed a checklist aimed at making simplification more routine in multilateral tax policymaking, including in the inclusive framework on base erosion and profit shifting, while ensuring any complexity is measured and intentional.

Developed and developing countries were divided on whether a new United Nations tax treaty should include arbitration as a potential tool to resolve tax disputes.

The OECD expects further work for “many years” implementing the global minimum tax along with designing its new system with the US, according to an organization official.

In the three years since its founding, Syntesia has rapidly become one of the European Commission's key suppliers of tax analysis, reflecting a quiet shift in how the EU institution sources policymaking evidence after LuxLeaks.

 Countries signaled broad support for an approach to the dispute resolution protocol to the U.N. tax convention, but EU countries and others cautioned against the protocol superseding existing dispute resolution mechanisms.

The OECD on November 17 published its 2025 report on tax administration issues and trends across 58 of its member jurisdictions, finding that 69 percent of tax administrations had incorporated artificial intelligence in their operations as of 2023 and that 24 percent planned to implement similar systems in the future as tax administrations continue to serve as the primary government bodies that collect revenue.

Mindy Herzfeld examines possible paths for the Supreme Court to strike down some of the president’s tariff powers and whether the Trump administration’s objectives could be achieved through a more sensible cross-border tax policy.

The Trump administration continued its efforts to secure commitments from trading partners not to impose digital services taxes, netting agreements with six more countries.

The United States secured pledges from five countries to not impose digital services taxes in the last week in its quest to stamp out the growth of the levies through trade deals.

U.N. tax leaders plan to release in 2026 an economic analysis exploring concepts and approaches on a protocol to the U.N. tax convention for the taxation of cross-border services.

High-income and low-income countries continue to disagree on aspects of a U.N. framework convention for international tax cooperation, with wealthy nations arguing against the inclusion of provisions they say might duplicate OECD work.

Napoleão Dagnese explores geopolitics, the data revolution, and the role of international taxation and multinationals in distributing power, profits, and development.

Reuven S. Avi-Yonah examines problems with the U.S. withholding tax regime and recommends that the United States abolish it, including withholding tax on fixed or determinable annual or periodic income.

Robert Goulder comments on the CJEU's decision in Arcomet, finding that intragroup profit adjustments are within the scope of VAT.

Countries on three continents objected to a draft UN tax treaty provision over concern it would infringe on their right to choose how to resolve domestic tax disputes.

Over a dozen countries called for removal of draft language in a UN tax treaty they claimed would undermine barriers to international tax competition erected by the Organization for Economic Cooperation and Development.

Chinese tax authorities ordered e-commerce giants including Amazon.com Inc. to hand over sales data for the first time, according to people familiar with the matter, in a rare move to crack down on tax evasion by merchants who use the online platforms for cross-border business.

Alexandra Sherwood examines the International Maritime Organization’s global emission pricing mechanism and its similarity to a tax, and she explains that without the typical safeguards such as judicial review found in sovereign taxation, the mechanism could face problems of accountability, double taxation, and institutional legitimacy.