Int'l Tax News

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

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.

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.

Countries in a United Nations committee remain divided over how a new treaty should revamp global tax rules, including how to redistribute the allocation of taxing rights.

The OECD on August 6 published a list of the first 14 jurisdictions to sign the Multilateral Competent Authority Agreement on the Exchange of GLOBE Information.

Eschewing more technical discussions, many countries said they wanted only high-level commitments on the taxation of cross-border services income in a U.N. tax convention.

Generous tax breaks for big businesses in the One Big Beautiful Bill Act (OBBBA, P.L. 119-21) could instead become a headache for those that find themselves unexpectedly running afoul of U.S. minimum tax regimes.

Daniele Majorana explains how the EU can progress toward its goals amid recent developments in global taxation.

Karl Berlin and Louise Blichfeldt Fjord analyze when the actions of a business carried out from a vessel at sea can create a permanent establishment under international agreements and model tax treaties.

Martins Arogie explains how Nigerian efforts to replace crude oil revenue with tax revenue has led to the country’s own version of the One Big Beautiful Bill Act, and he explores the implications for offshore businesses.

A Thai government commission has proposed amending the country’s legislation to add refundable tax credits to encourage activities like research and development in compliance with OECD pillar 2 global minimum tax rules.

The Australian Productivity Commission has advised cutting the corporate tax rate to 20 percent for most businesses to encourage investment and lift productivity in the country.

The future of France’s digital services tax is in the hands of the French Constitutional Council, which will soon determine whether the controversial measure is unlawful.

Pakistan has rolled back its newly enacted digital presence proceeds tax on companies operating outside the country in an apparent concession to the United States for securing an oil reserves development deal.

Cyprus has recently enacted significant amendments to its tax legislation, introducing robust defensive tax measures aimed at countering aggressive tax planning involving low-tax jurisdictions and non-cooperative jurisdictions, often referred to as “blacklisted” jurisdictions (BLJs).

The intensity of EU member state involvement in the U.N. tax talks could hinge on whether the EU delegation is allowed to join intersessional workstreams.

France will respect the application of the simplified and streamlined transfer pricing approach by a low-capacity jurisdiction with which it has a bilateral tax treaty in force, in line with the amount B political commitment.

 Mindy Herzfeld examines the One Big Beautiful Bill Act’s changes to the international tax regime, saying that while the regime’s foundation remains mostly intact and the changes are generally improvements, some of them interact in unexpected ways that taxpayers should consider carefully.

Mark R. Martin, Cameron Taheri, Mark J. Horowitz, Thomas D. Bettge, Caroline Conway, and Caleigh Wallace outline the IRS’s annual report on advance pricing agreements and offer country-specific insights for taxpayers navigating the evolving global tax landscape.

Reuven S. Avi-Yonah compares House and Senate sections of the One Big Beautiful Bill Act and examines the potential effect on international tax

Elizabeth J. Stevens and J. Clark Armitage critique Treasury regulations and IRS guidance governing periodic adjustments to the pricing of transfers of intangible property, and they analyze ways for controlled taxpayers to adapt to and mitigate the risk of such adjustments.

Ryan Bray, Matthew Brown, and Jose Rego argue that the removal of proposed section 899 from the One Big Beautiful Bill Act might not make things as simple for some U.S. taxpayers as it first appeared, saying uncertainties remain after the agreement between the United States and the other G7 countries.

Source countries — often developing countries or emerging economies — are advocating for a U.N. tax convention protocol that enables the taxation of cross-border services without permanent establishment.

Larissa Neumann and William R. Skinner review the One Big Beautiful Bill Act ramifications and the Facebook and Yum! Brands Inc. cases and explore the status of recent regulations and guidance.

Mexico still plans to implement the OECD’s amount B simplified and streamlined approach, and South Africa is interested in doing the same, according to a new batch of updated OECD transfer pricing profiles.

Lucas Martini de Aguiar analyzes the potential impact of new Brazilian legislation on nonresident investment in the stock market.

The tax guidance multinational corporations and international tax practitioners want to see most has nothing to do with the sweeping new tax law that was just enacted.

G20 finance ministers and central bank governors issued a communiqué following their July 17-18 meeting in South Africa, noting their continuing commitment to improving international tax cooperation by addressing concerns regarding global minimum taxes under pillar 2 of the OECD’s two-pillar global tax reform plan.

Several EU member states said it is not within the EU's competence to collect a financial contribution from companies to finance the bloc's budget and that such a measure would harm competitiveness.

The G20 will keep negotiations going on a proposal to shield U.S. companies from the application of some OECD pillar 2 global minimum tax rules, according to a communiqué issued after a key meeting.

Lee A. Sheppard examines a provision in the One Big Beautiful Bill Act that restores, with some exceptions for specified foreign parent situations, the prohibition on downward attribution that the Tax Cuts and Jobs Act repealed, saying that the IRS and Treasury will need to rescind or reengineer guidance issued while the prohibition was repealed.

The White House says the EU is committed to abandoning its future plans to impose network fees on big U.S. tech platforms; the European Commission is less sure.

The IRS and Treasury are contemplating the proper attribution method to determine the source of income for cloud transactions and are questioning how to evaluate relevant factors like intangible property.

The OECD on July 17 published a report — prepared ahead of the July 17-18 meeting of G20 finance ministers and central bank governors in South Africa — regarding recent developments in international tax cooperation, including its support of various G20 priorities such as tax transparency and the implementation of the base erosion and profit-shifting minimum standards.

Adam Kern analyzes how treating global intangible low-taxed income as an income inclusion rule will affect the stability of pillar 2.