2023

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.

Nana Ama Sarfo explores how some countries are using the revenue results of their digital services taxes — whether better or worse than expected — as justifications for expanding their measures.

Alina Miyake and Lucas de Lima Carvalho explore Brazil’s signing of the OECD multilateral instrument and the implications for Brazil's tax treaties.

Vietnam’s National Assembly has amended the Tax Administration Law to require online platforms to remit taxes on behalf of parties selling goods and services over their systems.

France's Directorate General of Public Finances has published a user guide for taxpayers required to file information returns under the country’s global anti-base-erosion rules, confirming plans to open a submission platform by May 2026.

The Australian Taxation Office has released final guidance on how it will grant full or partial exemptions for public reporting of multinational enterprises' tax information on a country-by-country basis.

Mukesh Butani, Shankey Agrawal, Harsh Shukla, Pratha Khanna, and Spandana Koona examine the impact of U.S. tariffs on global trade and offer recommendations for establishing treaty standards to protect against future uncertainties.

The OECD on December 9 published its 2025 tax revenue statistics report, finding that the average tax-to-GDP ratio across member jurisdictions increased from 33.7 percent to 34.1 percent between the 2023 and 2024 financial years, with social security contributions and personal income taxes accounting for the largest shares of revenue on average in 2023 at 25.5 percent and 23.7 percent, respectively.

Belgian Finance Minister Jan Jambon said the EU's evaluation of pillar 2 must account for the major political changes now underway around the world.

Michael N. Kandev examines current transfer pricing guidelines in Canada and compares them with proposed changes in the 2025 budget.

Mindy Herzfeld examines the headwinds facing the OECD pillar 2 global minimum tax project.

The Netherlands recognizes the importance of favorable treatment of substance-based nonrefundable tax credits under OECD global minimum tax rules, but restrictions are necessary to preserve pillar 2’s goals, a top Dutch tax official said.

 The following amicus curiae brief was filed with the Court of Justice of the European Union on November 19 by an international group of tax professors regarding a U.S. business lobby group’s legal challenge against Belgium’s undertaxed profits rule in American Free Enterprise Chamber of Commerce v. Ministerraad, C-519/25.

Nana Ama Sarfo discusses how the Trump administration’s efforts to combat discriminatory unilateral measures in the digital economy are extending past digital services taxes and including indirect taxes like value added taxes.

The U.K. government has confirmed it is now targeting 2027 for the implementation of OECD pillar 1 reforms that would require the rollback of digital services taxes, citing a delay in negotiations.

House Republican taxwriters revived a threat to institute retaliatory international taxes if global powers don’t show progress on the agreement to exempt American companies from some OECD global minimum tax rules by the end of 2025.

South Korea’s National Assembly has passed legislation increasing each of the country’s four corporate tax rates by 1 percentage point and establishing a tax scheme for “high-dividend companies" meant to revitalize capital markets.

Reuven S. Avi-Yonah examines the legislative history of the net controlled foreign corporation tested income and corporate alternative minimum tax regimes to determine whether pillar 2 can survive side by side with them.

It is vital that an international tax deal be promptly finalized to “provide certainty for U.S. companies and fair treatment for foreign companies who wish to invest in the United States,” House Ways and Means Tax Subcommittee Chair Mike Kelly, R-Pa., said in his opening statement at a December 3 hearing on global competitiveness.

 The United Kingdom will proceed with legislation to reform the country’s transfer pricing, permanent establishment, and diverted profits tax rules, while a matrix for related-party transactions will need to be significantly fleshed out through secondary legislation.

The OECD Global Forum on Transparency and Exchange of Information for Tax Purposes on December 2 published its 2025 annual report detailing the current progress on its cross-border administrative transparency initiative across 172 member jurisdictions, finding that over 32,000 information requests were sent during the 2024-2025 fiscal year and that over 70 jurisdictions are committed to implementing the cryptoasset reporting framework and sending out their first exchange requests by 2027.

Three European countries are progressing with the implementation of global minimum tax rules, with Switzerland and the United Kingdom amending their pillar 2 laws and Montenegro consulting on draft pillar 2 legislation.

The EU could take steps to harmonize wealth and cryptoasset taxation, digitalize tax administrations, and reduce compliance burdens without infringing on member states' national tax competence, according to a new study.

Thomas Horst, Thomas Meyer, and Priyan Thurairatnam present and analyze data regarding the disproportionate effects of the 2025 tariffs on large U.S. corporations.

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 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.

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.