2023

What was once too much of a nuisance for the US to regulate became too big of an economic force to ignore any longer.

As President Donald Trump’s tariffs make waves in the world economy, multinational companies are mulling what it could mean for their intangible assets like intellectual property and brand recognition.

Expansion of Canada’s power to gather tax information, as the government is proposing, would open companies and individuals to excessive penalties, more government mistakes, and expensive disputes, tax professionals say.

French President Emmanuel Macron vowed a strong response if any country takes measures that undermine Europe’s digital sovereignty.

Italy is preparing to repeal its digital services tax in the 2026 budget law, according to Finance Ministry sources, after the United States renewed threats to impose tariffs in response to unilateral levies on technology companies.

Reuven S. Avi-Yonah explores the possible outcome if the OECD were to recognize the U.S. global intangible low-taxed income tax as a legitimate pillar 2 income inclusion rule.

Robert Goulder examines the (few) pros and (many) cons of taxing exports.

President Donald Trump threatened to inflict “substantial” tariffs on countries that impose digital taxes just days after Meta Platforms Inc. Chief Executive Officer Mark Zuckerberg raised concerns about the levies during a White House meeting.

Countries that have imposed digital taxes on tech giants such as Amazon.com Inc. and Meta Platforms Inc. are again under threat of retaliatory tariffs from President Donald Trump, forcing them to decide whether to resist or give in to his demands.

The Mexican government plans to increase tariffs on China as part of its 2026 budget proposal next month, protecting the nation’s businesses from cheap imports and satisfying a longstanding demand of US President Donald Trump.

The European Commission denied targeting American companies and defended the EU’s right to regulate businesses within its borders following President Trump’s threats to impose substantial additional tariffs on countries that regulate big tech or impose digital services taxes.

House and Senate leaders will have to reach a deal on funding for the IRS, OECD, and the Justice Department’s plan to reorganize the Tax Division during the upcoming government funding process.

The EU Council’s Danish presidency wants the European Commission to explain how international tax developments could affect incentives to support the Clean Industrial Deal.

Anthony Stobart, Stefano Grilli, Hendrik Breimann, Irene Reoyo, Alice de Massiac, Kristina Adamson, and Shawn Porter summarize the qualified domestic minimum top-up tax rules in Canada, France, Germany, Italy, Spain, and the United Kingdom, providing examples of typical mergers and acquisitions transactions to illustrate their application.

India’s Prime Minister Narendra Modi is seeking to overhaul the country’s complex goods and services tax, in an attempt to boost domestic spending and cushion the economic blow of US tariffs.

The European Union hit back at US President Donald Trump’s claims that digital regulations abroad are unfair, a day after he threatened to impose tariffs and other penalties on countries that tax online services ranging from social media to e-commerce.

Australian Treasurer Jim Chalmers commended a report released by the country’s Productivity Commission that recommends cutting the corporate tax rate and imposing a new tax on cash flow to spur investment and growth.

Reuven S. Avi-Yonah, Jeffery M. Kadet, and Karen Sam refute certain criticism of the proposed cloud services sourcing rules released in January, and they suggest important amendments for Treasury and the IRS to consider in implementing the final regulation.

Craig A. Hillier and Yulia Kirillova review the status of pillar 2 in light of U.S. opposition and they suggest ways to adjust the structure to accommodate the concerns of the United States and other nations while maintaining some of its benefits.

More than two dozen countries criticized a system that would exempt American multinational companies from key parts of the global minimum tax, saying it would risk undermining the tax’s effectiveness, put non-US companies at a disadvantage, and challenge their own tax sovereignty.

US President Donald Trump threatened to impose fresh tariffs and export restrictions on advanced technology and semiconductors in retaliation against other nations’ digital services taxes that hit American technology companies.

Mindy Herzfeld argues that despite the Trump administration’s strong stance against foreign discriminatory taxes, it hasn't taken serious action against them, and says that the administration’s recent deal allowing manufacturers to export AI chips to China closely resembles the types of taxes it disapproves of from other countries.

U.N. countries have very different — and sometimes oppositional — approaches to allocating taxing rights in a digitalized economy, which could complicate negotiations around cross-border services taxation, according to a recent report.

The International Centre for Tax and Development on August 7 issued a policy brief regarding the trade-offs in the U.N. negotiations for protocol 1 to the framework convention on international tax cooperation, finding that protocol 1 needs to address ongoing cross-border taxation issues as digitalization rises; that tax policymaking must be intentional; and that the United States' exit from OECD negotiations limits the potential of a comprehensive international tax standard.

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

Building a better tax system in Australia is one of the 10 longer-term reform priorities announced by Treasurer Jim Chalmers following a highly anticipated productivity summit with key stakeholders.

Robert Goulder comments on the unexpectedly high U.S. tariffs imposed on Swiss imports.

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.

Treasury and the IRS have decided to withdraw the rules applying disregarded payment losses after concerns about statutory authority led to rounds of delays and additional carveouts.

The U.N. tax committee is looking for input on which tax policy issues it should focus on during its next five-year term.

The One Big Beautiful Bill Act’s suite of international tax reforms is likely to spur a surge in tax insurance activity as companies model out the new provisions and stake out uncertain new positions, insurers say.

A Slovakian minister said he intends to present a proposal to the country’s coalition government to impose a tax on large multinational companies providing digital services in Slovakia.

Daniel N. Shaviro compares the broad effect of digital services taxes and the OECD’s pillar 1, asking whether the emergence of the former in lieu of the latter is an unforeseen benefit to the United States.

Several country representatives have expressed support for the creation of a cooperative transfer pricing comparables database under a key protocol to the U.N. framework tax convention, but others warned the task wouldn’t be easy.

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 plans to adapt its transfer pricing guidelines to new realities like global mobility and artificial intelligence and to develop a common understanding of terms that are often disputed, an official said.

The lines between tax and trade policy are likely to become increasingly blurred as the Trump administration shifts its attention to disarming overseas digital services taxes, observers say.

The U.N. tax framework convention’s early protocol on services should incorporate fractional apportionment or formulary apportionment similar to amount A of pillar 1 of the OECD’s two-pillar global tax reform plan, the G24 said.

The design of an own resource to finance the EU budget as a contribution levied on high-turnover companies raises legal questions.

Pramod Kumar Siva and William H. Byrnes explain why the UTPR, formerly known as the undertaxed profits rule, is an unlawful extraterritorial tax that contravenes legal norms, generates economic distortions, and diminishes international tax cooperation.

A new Eurobarometer shows that 80 percent of Europeans polled want large multinational enterprises to pay a minimum amount of tax in each of their countries of operation, an idea that finds a majority in all member states.

Muhammad Ashfaq Ahmed examines changes to the U.N. Model Tax Convention 2025 from their genesis, evolution, and development, to their finalization, approval, and future implications from both an international tax law and international political economy perspective.

Mindy Herzfeld examines the developments that led to the recent G7 agreement to respect the U.S. tax regime as “a side-by-side system” with the OECD’s pillar 2 and what that means for the future of digital services taxes and tax multilateralism more broadly.

The EU has “a quite negative view” on the United States' proposal to credit its minimum tax rules when calculating their qualified domestic minimum top-up taxes under pillar 2, according to a top European Commission official.

In a letter to the editor, Jefferson VanderWolk argues that pillar 2 should be abandoned rather than an attempt be made to salvage it.

Nana Ama Sarfo discusses Nigeria's new tax reform legislation and its emphasis on base broadening and tax enforcement.

Robert Goulder comments on the recent G7 agreement regarding pillar 2 and the withdrawal of proposed section 899.

Governments across the globe breathed a sigh of relief when Republicans dropped section 899, but slow progress on the terms of the deal reached by the G7 could see it return with a vengeance.

Germany’s economy minister has rejected the idea of imposing a digital tax on U.S. technology companies that the minister of state for culture had said the government was drafting in May.