2026
OECD Further Updates Global Minimum Tax Commentary
The GLOBE consolidated commentary was updated on May 28 and builds on previous version issues in May 2025. Important elements of this package include the side-by-side safe harbor, the ultimate parent entity (UPE) safe harbor, the simplified effective tax safe harbor, the substance-based tax incentive safe harbor, and the one-year extension of the country-by-country reporting safe harbor.
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Click here for GLOBE consolidated commentary.
Panama Hits Shell Companies With 15 Percent Passive Income Tax
Panama’s National Assembly approved a 15% tax on the passive income of locally domiciled multinational entities that fail to demonstrate real economic activity. The bill also modernizes Panama’s concept of permanent establishment in accordance with international standards, introduces an anti-abuse clause, and reinforces guarantees regarding the confidentiality and protection of tax information. Panama hopes that this will remove it from the EU’s grey lists of noncooperative tax jurisdictions.
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U.N. Tax Convention Contains Gaps in Anti-Harmful Tax Policies
Several non-OECD countries believe the U.N. tax convention contains critical gaps in its approach to tackling harmful tax policies and push for developing a fairer international tax system to address these harmful tax practices. Some leaders believe that progress on the U.N. tax convention have slowed with the exit of the U.S. from U.N. talks.
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Dutch Academics Question EU Implementation of Pillar 2 Carveout
Two Dutch academics see constitutional and state aid problems arising from the EC’s implementation of the side-by-side safe harbor. This safe harbor, which exempts corporate groups from the income inclusion rule and undertaxed profits rule if they are headquartered in a qualifying jurisdiction (U.S. is the only jurisdiction with this status), is believed to allow a non-EU body to write EU law.
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OECD Finds Corporate Tax Regimes Can Disfavor Young, Small Firms
An OECD report published Wednesday concluded that corporate income tax regimes can disproportionately disadvantage younger and smaller businesses by favoring larger multinational enterprises with greater tax planning capacity and access to specialized compliance resources. The report also raises questions about whether current international tax frameworks adequately balance revenue collection objectives with the need to support market entry and growth among smaller firms operating in increasingly globalized markets.
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Data Center Lag Risks Irish Corporate Tax Receipts, Group Warns
An Irish digital infrastructure group warned that delays in expanding data center and energy capacity could threaten Ireland’s corporate tax base by prompting multinational technology companies to relocate intellectual property and future investment elsewhere.
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Private Equity-Owned Firms Look to Avoid UK Tax Reporting Push
Private equity-backed companies are seeking exemptions from proposed UK tax reporting rules for “close companies,” arguing the measures were designed for small closely controlled businesses rather than large investment-backed corporate groups. The proposal highlights how technical ownership rules can inadvertently expand compliance obligations for multinational investment structures and private funds. The debate also reflects broader tensions between tax transparency initiatives and the administrative burdens imposed on complex cross-border corporate ownership arrangements.
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Europe’s Voice at UN Tax Talks Grows Despite US Hostility
European countries are increasingly participating in United Nations negotiations aimed at expanding developing countries’ ability to tax remote and digital businesses, reflecting growing dissatisfaction with stalled OECD digital tax discussions and declining confidence in US cooperation. The negotiations center on replacing traditional physical presence standards with broader taxing rights over multinational enterprises operating digitally across borders.
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Home and away: When does working remotely across borders create a taxable presence?
The OECD blog explains how cross-border remote work may affect whether an employer has a taxable presence in another country under Article 5(1) of the OECD Model Tax Convention. It highlights the November 2025 OECD Model Commentary updates, which clarify that an employee working from home abroad does not automatically create a permanent establishment, especially where the arrangement is part-time or driven by personal preference rather than business necessity.
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