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UN Tackles Headwinds in Shaping Tech Transfer Pricing Guidance (07/10/2026)

  • By James Munson

Overcoming data access and personnel limitations is among top challenges for a United Nations effort to help developing countries expand their enforcement of transfer pricing in the tech sector.

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OECD Urges Patience After Rocky Start to Minimum Tax Filings (07/10/2026)

  • By Saim Saeed

Companies should give the OECD’s latest simplification measures time to work after a difficult first year of compliance with the global minimum tax rules, a senior OECD official said.

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Profit-Shifting Risks High Despite Minimum Tax Deal, UK MPs Say

  • By Somesh Jha

UK lawmakers warn that companies still pose “significantly high” risks of diverting profits despite the new global minimum tax deal and asked the tax authority to share progress on implementation within a year.

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EU Parliament Adopts Tax Resolution to Promote Competitiveness

  • By Lauren Vella

Members of EU Parliament adopted a resolution for tax proposals meant to boost competitiveness in the bloc.

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Public Tax Transparency Rules ‘Very Dangerous,’ US Official Says

  • By Saim Saeed

New tax reporting rules in the European Union for multinationals deter growth and risk creating a “culture of damnation,” according to a US official.

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From Sugar Refiners to Norway, Hundreds Aim to Avoid New Tariffs (07/07/2026)

  • By Ethan Schenker

Hundreds of companies, trade associations and foreign governments are asking for their supply chains to be spared as the Trump administration weighs imposing a new round of widespread tariffs later this month.

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US Tariff Threat Is an Ill-Advised Digital Services Tax Reaction (07/07/2026)

  • By Andrew Leahey

President Donald Trump’s threat to impose 100% tariffs on countries with digital services taxes is an attempt to use consumer-funded trade pain to shield big tech from foreign tax bills, rather than a defense of the US tax system. It would be better to move toward a coherent multilateral framework that trades repeal of unilateral DSTs for clear rules on where digital profits can be taxed.

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Forced-Labor Hearings to Spark Fresh Tariff Debate: Supply Lines (07/07/2026)

  • By Brendan Murray

A three-day hearing hosted by the US Trade Representative kicks off on Tuesday, bringing together industries and government officials trying to plead their case for or against more tariffs from the Trump administration.

 

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Magnifica Humanitas: What Pope Leo XIV’s Encyclical Tells Us About Digital Service Taxes

  • By Raffaele Russo

This post examines digital services taxes in light of broader debates over taxation, digitalization, and artificial intelligence. It discusses DSTs as a response to the stalled implementation of OECD Pillar One Amount A, and considers whether user data, AI-driven monetization, and different digital business models may justify more refined DST rules, including differentiated rates and revised scope for the AI economy.

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Burnham Floats Warehouse Tax Hike to Benefit High Street (1) (07/03/2026)

  • By Chloe Chaplain

Andy Burnham said he would increase business rates on warehouse-based companies in order to lower costs for high street shops and bars as he set out details of what he would do if he continues on his path to becoming the next prime minister.

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New Arbitration Group Seen Aiding EU Tax Dispute Resolution (07/03/2026)

  • By Ryan Hogg

An ambitious project to strengthen European countries’ resolution of cross-border tax and transfer pricing disputes—if it fulfills its vision—will pay off with upgraded standards, faster processes, and more certainty for multinational companies, tax professionals say.

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Irish Corporation Tax Receipts Rise Despite Reshoring Fears (1) (07/03/2026)

  • By Olivia Fletcher

Irish corporate tax receipts rose in the first half of the year, despite concerns that American firms would reshore profits as part of President Donald Trump’s vow to bring US company profits home.

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America 250 Edition: Tariff Threats, USMCA, and A History

  • By Jacob Jensen

This piece discusses President Trump’s threat to impose a 100 percent tariff on countries that apply digital services taxes to U.S. companies. It explains that the administration would likely need to proceed through established trade-law mechanisms, such as Section 301 or Section 232 investigations, and places the proposal within broader U.S. objections to foreign DSTs targeting American technology companies.

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Digital Levy Should Be Part of EU Budget, Representative Says (07/02/2026)

  • By Saim Saeed

The European Union should include a digital levy targeting large tech companies as it searches for new revenue to finance defense spending and repay joint debt, Czech representative Danuše Nerudová said on July 2, 2026.

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Businesses Urge EU to Resist Diluting Tax Simplification Plan (07/02/2026)

  • By Saim Saeed

A group representing Europe’s biggest companies called on EU governments July 2, 2026 not to water down the European Commission’s tax simplification bills, warning that changes could undermine efforts to reduce regulatory burdens and boost the bloc’s competitiveness.

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Fight Brewing Over MNE Public Tax Disclosures

  • By Sarah Paez

The first public country-by-country reports under the EU directive—from Microsoft, Procter & Gamble, and others—drew praise for transparency but warnings from the OECD, business groups, and companies against misreading the data. Microsoft booked 38.1 percent of its worldwide profits in Ireland despite housing under 3 percent of its workforce there, while P&G reported $114 million in tax-free Luxembourg profit tied to a now-liquidated entity, fueling debate over whether the disclosures reveal avoidance or just an incomplete picture.

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Corporate Tax Perks Decrease Rates in Latin American Countries (06/30/2026)

  • By Lauren Vella

Some corporate tax incentives doled out by Latin American countries significantly reduce their effective tax rates, a new report from the OECD found.

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Germany Parliamentary Committee Rejects Proposed Digital Tax

  • By Stephanie Soong Johnston

Germany's Bundestag Finance Committee rejected a Greens proposal for a 10 percent digital services tax on big tech, whose German effective tax rate runs about 3.4 percent versus up to 30 percent for domestic firms; the CDU/CSU cited legal concerns and the SPD called it premature. The Greens vow to keep pushing, preferring a coordinated EU-level DST over the U.S.-secured pillar 2 carveout.

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Microsoft’s Irish Hub Is Profit Powerhouse

  • By Richard Rubin
  • By Theo Francis

Microsoft's first public country-by-country report under new EU disclosure rules shows the company concentrated 38.1% of its global pretax profit in its Irish hub, where it employs under 7,000 people but generates pretax profit per employee 13 times the worldwide average. The disclosure, filed because Microsoft's fiscal year ends in late June, offers an early look at how multinationals structure intercompany transactions across jurisdictions ahead of similar reporting requirements taking effect in Australia and under the FASB later this year.

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Canada’s Cross-Border Tax Avoidance Plan Too Sweeping, Pros Say (06/29/2026)

  • By James Munson

Canada’s decision to deviate from global norms in targeting cross-border tax avoidance structures would weaken investment and raise costs for companies, especially those working with entities in the US, tax professionals say.

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Drug Pricing Rules and Tariffs Reshape Transfer Pricing for IP (06/29/2026)

  • By Robin Hart
  • By Arindam Mitra

Recent US policy changes are forcing life sciences companies to rethink core commercial decisions in ways that require a reexamination of how intercompany pricing for intangible property is structured and defended. The policy changes come from two directions: measures designed to reduce US drug prices, such as most-favored nation pricing; and tariffs.

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OECD Projects Less Revenue With Side-by-Side Minimum Tax Package

  • By Stephanie Soong Johnston

An OECD tax official said the side-by-side package's substance-based tax incentive safe harbor—more than the U.S. safe harbor itself—is driving down projected pillar 2 revenue, since it lets jurisdictions use qualified tax incentives to attract investment while capping top-up tax exposure. The OECD plans to release an updated global minimum tax impact assessment incorporating this and other recent implementation data, following its 2020 initial assessment and 2024 working paper.

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ATAD Evaluation Flags General Antiabuse Rule’s Legal Uncertainty

  • By Elodie Lamer

A European Commission staff working document evaluating ATAD found stakeholders view the GAAR's broad, discretionary scope as a source of legal uncertainty, prompting debate over whether Unshell's economic substance criteria should instead be folded into the GAAR or DAC6's hallmark D2—a question the commission has deferred by proposing to address substance via future EU Council implementing acts. The evaluation also flags unresolved tension between the GAAR and pillar 2, with the tax simplification omnibus now clarifying that the GAAR extends to top-up taxes, even as businesses argue CFC rules are increasingly redundant alongside pillar 2.

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U.S. Tariff Threat Looms Over Digital Tax Talks

  • By Sarah Paez

President Trump threatened a 100 percent tariff on any country advancing digital services tax legislation, declaring it would apply immediately and override existing trade deals—prompting the European Commission to defend DSTs as a nondiscriminatory sovereign right and warn it will "respond swiftly and decisively" if the EU is targeted. The clash surfaces just as global digital tax talks resume, with German officials pressing for a coordinated international approach on nexus and profit allocation even as valuation questions grow more complex amid rising AI use.

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Week in Insights: Tax Cuts and Jobs Act Met Its Goal at a Cost (06/28/2026)

  • By Andrew Leahey

new economics paper complicates the story about the Tax Cuts and Jobs Act of 2017. For years, supporters have deemed it a pro-growth success, while critics have called it an expensive giveaway tilted toward corporations and high earners.

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Services Taxation Major Sticking Point in UN Talks, Chair Says (06/26/2026)

  • By James Munson

Disagreements over how to tax cross-border services are proving to be a major hurdle for negotiators working on a United Nations global tax agreement, the head of the negotiating committee said Friday.

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Tax Incentives Continue to Dominate Governments’ R&D Support (06/26/2026)

  • By Ryan Hogg

Government support for research and development through tax incentives has more than doubled over two decades, new OECD data shows.

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Trump Vows 100% Tariff If Countries Impose Digital Services Tax (06/26/2026)

  • By Gabriella Borter

President Trump says any country that imposes a digital services tax on American companies “will immediately be met with a 100% TARIFF” on all goods sent to the US.

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Tax AI Where Profits Are Created, OpenAI Executive Says (06/26/2026)

  • By Somesh Jha

Tax policy for artificial intelligence should focus on where profits are created, a top OpenAI executive said on June 26,2026.

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Trump threatens 100% tariff on any country that imposes digital services tax

  • By Doina Chiacu
  • By David Lawder

This article reports that President Trump threatened a 100% tariff on goods from any country imposing a digital services tax on U.S. companies. The article links the threat to France’s existing digital services tax on revenues from online marketplaces and advertising, as well as broader U.S. objections to European DSTs that the U.S. Trade Representative has argued discriminate against American technology companies.

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Government R&D Tax Supports Doubled in 20 Years, OECD Finds

  • By Sarah Paez

Tax incentives now account for 60 percent of government support for business R&D across OECD countries, up from 28 percent in 2004, according to an updated OECD database covering 56 countries. The data also show R&D tax relief has tripled as a share of government budget allocations, with Portugal, Iceland, the U.K., France, and China leading in tax relief as a share of GDP.
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Trump Threatens 100% Tariff on European Countries That Impose Digital Services Tax

  • By Gavin Bade

President Trump threatened to impose a 100% tariff on goods from any European country that enacts a Digital Services Tax on U.S. tech companies, warning the levy would supersede the existing EU-U.S. trade deal. The threat raises fresh trade tensions a day after the EU approved tariff reductions under that agreement, and comes amid legal uncertainty over whether Trump has the authority to impose such tariffs immediately.
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ECJ Adviser Backs EU Probe Into Mead Johnson Gibraltar Tax Break (06/25/2026)

  • By Jan Stojaspal

The European Court of Justice should back the European Commission’s decision to extend a state aid investigation into whether a Gibraltar entity of the Mead Johnson Nutrition group received preferential tax treatment, an adviser to the court wrote on June 25, 2026.

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Tax Simplification Gains Outweigh Revenue Losses, Hoekstra Says

  • By Elodie Lamer

EU Tax Commissioner Wopke Hoekstra defended the European Commission's tax simplification omnibus, which promises to save companies €8 billion by reducing duplicative reporting and easing pillar 2-related antiabuse obligations, arguing the package's budgetary impact on member states is negligible by comparison. Hoekstra also signaled openness to an EU-wide digital services tax as a potential future revenue source if pillar 1 negotiations fail, while cautioning against reading broader harmonization ambitions into the proposal.
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EU’s DAC Recast Facilitates Future Pillar 2 Reporting Changes

  • By Sophie Petitjean

The European Commission's proposed recast of the EU's administrative cooperation directives would consolidate all DAC rules into a single framework, cut €1.283 billion in compliance costs, and empower the commission to adopt implementing acts to align EU rules with future OECD GLOBE information return updates without requiring unanimous legislative amendments. Key changes include easing DAC6 reporting burdens for pillar 2 in-scope multinationals, raising DAC7 digital platform reporting thresholds, and streamlining DAC4 and DAC9 notification requirements.
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Pillar 2 Reshuffles the Cards of EU Antiabuse Rules

  • By Elodie Lamer

The European Commission's tax simplification omnibus proposes sweeping changes to EU antiabuse rules, including exempting pillar 2 companies from controlled foreign company rules, mandating a €3 million interest deduction threshold, and introducing a full withholding tax exemption on intragroup interest, royalties, and dividends effective 2037. The package also introduces a minimum R&D allowance standard within the ATAD, with the commission citing pillar 2 as justification for rolling back overlapping antiabuse measures that risk creating double taxation.
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Italy Reports DST Surge, Weak Global Minimum Tax Revenue

  • By Matteo Rizzi

Italy's Court of Auditors reported that the country's digital services tax generated €637 million in 2025, a 40 percent increase from the prior year, while its first-year global minimum tax revenue came in at just €46 million against a forecast of €381 million. The report also noted continued growth in Italy's flat tax regime for high-net-worth individuals relocating to Italy, with the annual substitute tax now set at €300,000 following successive increases.
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EU Proposes Tax Simplification Measures in Bid to Boost Business

  • By Saim Saeed

The European Union unveiled a new package to overhaul the bloc’s tax rules on June 24, 2026, the latest effort by Brussels to cut red tape and reduce the regulatory burden on business.

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European Commission proposes landmark tax simplification package to streamline compliance and boost competitiveness

  • By European Commission - Directorate-General for Taxation and Customs Union

This official EU item describes a tax simplification package aimed at reducing compliance burdens and modernising the EU direct tax framework. The proposals would remove withholding taxes on certain cross-border intra-EU payments, streamline the interaction between CFC rules and Pillar Two, strengthen cross-border tax dispute resolution, and simplify reporting obligations under the Directive on Administrative Cooperation, country-by-country reporting, and top-up tax information returns.

To read the full article, click here.

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OECD Aware of Issues With Pillar 2 and Investment Treaties

  • By Sarah Paez

OECD officials and tax experts warned that bilateral investment treaty protections in many countries could complicate or trigger arbitration against states implementing qualified domestic minimum top-up taxes, with one analysis suggesting 90 percent of existing investment treaties could expose such measures to investor challenges. The inclusive framework is working toward a coordinated solution, while multinationals and host countries weigh restructuring investments or renegotiating agreements to avoid disputes.
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AI Has No Place in Global Digital Tax Talks, US Official Says (06/23/2026) Author: Lauren Vella

  • By Lauren Vella

Artificial intelligence doesn’t belong in the OECD-led discussions about taxing the digital economy, the top US delegate to the organization said on June 23, 2026.

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Fragmented Filings Complicated Access to EU Public CbC Data

  • By Elodie Lamer

A Fair Tax Foundation review of 302 EU public country-by-country reports found that only 58 percent of companies complied solidly with the directive, with some multinationals filing fragmented single-country disclosures rather than consolidated group-wide reports. U.S. companies and the pharmaceutical sector were the worst performers, and advocates flagged the lack of a central repository as a significant barrier to accessibility.
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2025 MAP Paradigm Shift: The GATS Carveout and Amount B

  • By Mari Takahashi

Takahashi explores the 2025 updates to the OECD and U.N. model conventions and explains how the codification of the General Agreement on Trade in Services carveout and the standardization of amount B establishes the mutual agreement procedure as a strategic buffer to limit or reduce geopolitical friction.
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OECD to Release Data on Impact of US Global Tax Carve-Out (1) (06/22/2026)

  • By Lauren Vella

The OECD plans to release a report in July on the impact of the global minimum tax following a January agreement that carves out US multinationals from key parts of the minimum levy’s framework.

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EP Political Groups Lament Pillar 2 Side-by-Side Deal

  • By Elodie Lamer

MEPs across all major political groups pushed back on the EU's side-by-side package shielding U.S. multinationals from most pillar 2 obligations, warning it creates competitive disadvantages for European businesses and undermines the global minimum tax framework. Several groups also called on the commission to withdraw or overhaul the BEFIT corporate tax harmonization proposal over its incompatibilities with pillar 2.
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U.N. to Issue Deeper Report on Tax Cooperation Progress in 2027

  • By Sarah Paez

The U.N. and a task force of over 60 international institutions plan to publish a detailed 2027 report tracking countries' progress on the Sevilla Commitment, a 2025 agreement aimed at strengthening tax cooperation and boosting domestic resource mobilization in developing countries. The report will draw on the OECD's global revenue statistics tool to measure progress across commitments including tax transparency, taxation of high-net-worth individuals, and evidence-based tax incentive reform.
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German Ministry of Finance Finalizes Landmark PE Guidance

  • By Alexander F. Peter

Germany released its first major overhaul of permanent establishment administrative guidance in over 25 years, updating a 1999 circular to address digital services, remote work, and complex supply chains. The final version incorporates some stakeholder feedback from a February draft but leaves several issues unresolved, including guidance on partnerships, service PEs, and digital business models.
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Netherlands Holds Back on Taxing Windfall Oil Profits

  • By Olaf Geurts

The Dutch government said it will not impose an additional levy on oil companies' excess profits unless the European Commission puts forward an EU-level proposal, citing legal risks after 33 ongoing challenges to its 2022 solidarity contribution have put €2.7 billion in Dutch revenue at stake. The position leaves the Netherlands at a standstill despite parliamentary pressure to redistribute windfall profits to households amid rising energy prices tied to the war in Iran.
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Coke Takes on IRS With $20 Billion at Stake

  • By Richard Rubin

Coca-Cola and the IRS are heading to the 11th U.S. Circuit Court of Appeals in a long-running transfer pricing dispute over whether the company improperly shifted profits to low-tax foreign subsidiaries through its internal "10-50-50" method. A loss for Coca-Cola could trigger over $20 billion in back taxes, interest, and a higher ongoing effective tax rate, while a win would relieve a decade-long liability and offer reassurance to multinationals facing similar IRS scrutiny.
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Trump Poised to Roll Out New Tariffs as He Refunds the Old Ones

  • By Alicia Diaz

Tariff revenue is now flowing out of the US Treasury’s coffers faster than it’s coming in, with nearly $22 billion in unlawfully collected duties reimbursed to importers in May.

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