EU Council Announces Agreement on Information Exchange Directive
The EU Council announced that it has reached a final agreement on the ninth directive on administrative cooperation (DAC9) that will implement the global minimum information exchange standard under the OECD’s two-pillar tax reform plan, noting that member states are required to enforce DAC9 by December 31.
EU Commission Reports on 2023 Tax Trends
The EU Commission has announced the availability of tax trend data from 2023, noting that EU member states collected €6.7 billion in taxes — a 4.7 percent rise from 2022 — with increases in labor taxes and capital taxes of 5.9 percent and 4.5 percent, respectively.
Big Pharma Profits Stay Outside the United States
Martin A. Sullivan examines recent Form 10-K data from big pharmaceutical companies indicating that there is more worldwide, before-tax profit shifting outside the United States since passage of the Tax Cuts and Jobs Act.
NFTC Comments on Transfer Pricing Approach Consultation
The National Foreign Trade Council in a March 7 letter responded to the IRS’s public consultation regarding Notice 2025-4, which outlines the IRS and Treasury’s plan to propose regulations that are compliant with the OECD’s simplified amount B standard, urging Treasury and the IRS to expand the transfer pricing approach to include more industries and services and provide necessary guidance.
USCIB Calls for U.S. Leadership on Widespread Amount B Adoption
The United States must keep pushing for broader implementation of the amount B simplified and streamlined transfer pricing approach to avoid complexity and current controversy levels, the U.S. Council for International Business said.
EU Envoys Fail to Reach Agreement on DAC9
Once again, EU member states couldn’t agree on how to make future updates to the ninth directive on administrative cooperation, which transposes the OECD's standard global minimum tax information return into EU law.
Business Groups Call for U.S. Action at WTO on Digital Taxes
The United States should act at the WTO level to push back against other countries’ digital services taxes and similar measures that extract revenue from U.S. exports of digital products and services, business groups said.
China Targets U.S. Farm Products With Retaliatory Tariffs
China has responded to President Trump's decision to implement new tariffs against Chinese imports by targeting American imports with a second round of retaliatory tariffs that threaten to disrupt agricultural trade.
Trump’s Ambiguous Statements Throw EU Observers Off Balance
The Trump administration’s executive order disengaging from the OECD’s global tax plan and threatening retaliatory measures describes some actions that have never been taken and are legally questionable, further fueling global uncertainty, observers said.
G20 Ministers Note Sovereignty Amid Global Tax Deal Talks
G20 members have observed recent progress on the OECD’s two-pillar global tax plan, recognizing countries’ autonomy while backing quick adoption of the reforms, according to a summary of a key G20 meeting.
The Effect of Digital IP on Taxation and Transfer Pricing
Paul Glunt, Andrew Vickrey, and Jack O’Meara highlight examples of the digital transformation that is creating transfer pricing issues for multinational enterprises unique to the transfer or licensing of digital intangible property, and explain how investments in digital can address these issues and create value.
G20 Leaders Summarize Key Meeting on OECD’s Two-Pillar Solution
The G20 issued a summary of the February 26-27 meeting of finance ministers and central bank governors regarding the progress of implementing provisions within the OECD's two-pillar global tax reform solution, expressing support for international tax policy cooperation within the parameters of member jurisdictions' autonomy and compliance with the OECD's standards and voicing concern over developing countries' difficulty in benefiting from international tax changes.
OECD Working Paper Recommends Targeted Capital Gains Tax Relief
OECD countries should offer targeted capital gains tax relief instead of broad relief in order to decrease tax avoidance opportunities and discourage asset holding to delay tax payment, according to an OECD working paper.
White House Memo Promises Action Against Foreign Taxes
The Trump administration will respond to discriminatory taxes by foreign governments by imposing tariffs “and taking such other responsive actions necessary to mitigate the harm to the United States and to repair any resulting imbalance,” the White House said in a February 21 memo.
What Is an Applicable Corporation Under the Corporate AMT?
Kimberly S. Blanchard explains why section 59(k) and the proposed regulations are unclear and suggests an alternative, straightforward approach to the rules for foreign-parented multinational groups.
Donald Trump considers tariffs to counter digital services taxes on Big Tech
Donald Trump is considering tariffs on countries that levy digital services taxes against American companies and tightening rules on Chinese investment in the US as he widens the scope of his global trade war.
Trump’s Growing Focus on Tariff Revenue Raises Trade War Odds
President Donald Trump and his economic team are increasingly focusing on the revenues his tariffs would generate as he seeks to get tax cuts through Congress, pointing to an ominous path ahead for countries trying to avoid a trade war.
Reports of Pillar 2’s Death Are Greatly Exaggerated
Adam Kern examines President Trump’s executive memorandum on the global tax deal, arguing that it will have a limited effect on the stability of pillar 2 because the United States maintains the global intangible low-taxed income structure and the strategic dynamics that support pillar 2 thus remain largely intact.
EU to Consider Factoring Global Trends in Decluttering Agenda
The EU Council’s Polish presidency will ask member states whether to include international tax developments in their draft conclusions on a “future-proof tax policy which contributes to the competitiveness of the EU.”
Sovereignty, Sins, and the Reassertion of Primary Taxing Rights by the United States
Michael J. Graetz argues that the United States must reassert its primary taxing rights over income long conceded to other countries, especially income from intellectual property created in the United States, and he explains some changes necessary to make that happen.
EU Commission Answers Questions on U.S. Tariff Policy
The European Commission released a Q&A document regarding the United States' reciprocal tariff policy, including guidance on VAT in relation to tariffs; the EU's trade surplus rules; average tariff rates on both EU and U.S. imports; and asymmetrical tariff structures.