Int'l Tax News

On a frigid Thursday last December, 50 finance and technology experts shuffled into the International Monetary Fund’s Washington, DC, headquarters with a dire mission: to war-game how artificial intelligence might upend the global economy.

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The United Kingdom HM Revenue and Customs July 13 issued a policy paper on proposed finance bill measures to implement the OECD side-by-side package and updated administrative guidance to the Pillar 2 Global Anti-Base Erosion (GloBE) Model Rules, for purposes of the multinational top-up tax (MTT) and domestic top-up tax (DTT) for multinational enterprise (MNE) and large domestic groups with annual global revenues exceeding 750 million euros (US$858.8 million). The proposal includes measures to: 1) introduce side-by-side, ultimate parent entity (UPE), substance-based tax incentive, and simplified effective tax rate (ETR) safe harbors; 2) extend the transitional safe harbor election to accounting periods beginning on or before Dec. 31, 2027, and ending on or before June 30, 2029, effective for accounting periods beginning on or after Dec. 31, 2023; and 3) amend rules for discontinued operations, companies in distress, the election to treat certain top-up amounts as zero, and DTT determinations for group members. [United Kingdom, Government Portal, 07/13/26] .

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This OECD announcement presents updated analysis of the economic impact of the Global Minimum Tax, combining new estimates with preliminary evidence from its first year of implementation. It highlights expected increases in multinational effective tax rates, reductions in tax rate differentials and profit shifting, and higher global corporate income tax revenues, while preliminary 2024 data show no statistically significant negative effects on investment or employment. The announcement also places the findings in the context of BEPS reduction and broader international tax cooperation.

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This official USTR announcement imposes a 25 percent tariff on certain Brazilian imports following a Section 301 investigation into Brazilian trade practices. The investigation addressed measures involving digital trade and electronic payment services, preferential tariffs, intellectual property, ethanol market access, and other cross-border trade issues. The action reflects the use of tariffs and trade enforcement measures in response to disputed foreign economic policies.

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As global competition for mobile capital intensifies, tax administration is increasingly viewed as a core component of a jurisdiction’s investment offering. The UK’s Advance Tax Certainty Service, or ATCS, reflects this shift, positioning tax certainty as a strategic lever to enhance the attractiveness of the UK for major long-term investments.

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The OECD’s agreement to exempt US multinationals from key parts of the global minimum tax framework is expected to reduce revenues generated from the levy.

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The European Commission justified provisions in its tax simplification bill that leave out the largest multinationals from some anti-tax avoidance rules and reporting obligations, arguing that the global minimum tax insures against most forms of tax evasion.

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The UK is proposing to make its windfall profits tax on oil and gas permanent, with a new levy that would extend the windfall beyond its current expiration in 2030.

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The UK released its latest consultation document on the International Controlled Transactions Schedule, or ICTS, on June 16. This new annual filing requirement will transform transfer pricing risk assessments for both the UK tax authority, HM Revenue & Customs, and taxpayers, shifting from a documentation-focused process to a data-driven one.

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

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

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

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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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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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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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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.

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