2026

Fragmented Filings Complicated Access to EU Public CbC Data
A Fair Tax Foundation review of 302 EU public country-by-country reports found that only 58 percent of companies complied solidly with the directive, with some multinationals filing fragmented single-country disclosures rather than consolidated group-wide reports. U.S. companies and the pharmaceutical sector were the worst performers, and advocates flagged the lack of a central repository as a significant barrier to accessibility.
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2025 MAP Paradigm Shift: The GATS Carveout and Amount B
Takahashi explores the 2025 updates to the OECD and U.N. model conventions and explains how the codification of the General Agreement on Trade in Services carveout and the standardization of amount B establishes the mutual agreement procedure as a strategic buffer to limit or reduce geopolitical friction.
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OECD to Release Data on Impact of US Global Tax Carve-Out (1) (06/22/2026)

The OECD plans to release a report in July on the impact of the global minimum tax following a January agreement that carves out US multinationals from key parts of the minimum levy’s framework.

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EP Political Groups Lament Pillar 2 Side-by-Side Deal
MEPs across all major political groups pushed back on the EU's side-by-side package shielding U.S. multinationals from most pillar 2 obligations, warning it creates competitive disadvantages for European businesses and undermines the global minimum tax framework. Several groups also called on the commission to withdraw or overhaul the BEFIT corporate tax harmonization proposal over its incompatibilities with pillar 2.
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U.N. to Issue Deeper Report on Tax Cooperation Progress in 2027
The U.N. and a task force of over 60 international institutions plan to publish a detailed 2027 report tracking countries' progress on the Sevilla Commitment, a 2025 agreement aimed at strengthening tax cooperation and boosting domestic resource mobilization in developing countries. The report will draw on the OECD's global revenue statistics tool to measure progress across commitments including tax transparency, taxation of high-net-worth individuals, and evidence-based tax incentive reform.
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German Ministry of Finance Finalizes Landmark PE Guidance
Germany released its first major overhaul of permanent establishment administrative guidance in over 25 years, updating a 1999 circular to address digital services, remote work, and complex supply chains. The final version incorporates some stakeholder feedback from a February draft but leaves several issues unresolved, including guidance on partnerships, service PEs, and digital business models.
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Netherlands Holds Back on Taxing Windfall Oil Profits
The Dutch government said it will not impose an additional levy on oil companies' excess profits unless the European Commission puts forward an EU-level proposal, citing legal risks after 33 ongoing challenges to its 2022 solidarity contribution have put €2.7 billion in Dutch revenue at stake. The position leaves the Netherlands at a standstill despite parliamentary pressure to redistribute windfall profits to households amid rising energy prices tied to the war in Iran.
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Coke Takes on IRS With $20 Billion at Stake
Coca-Cola and the IRS are heading to the 11th U.S. Circuit Court of Appeals in a long-running transfer pricing dispute over whether the company improperly shifted profits to low-tax foreign subsidiaries through its internal "10-50-50" method. A loss for Coca-Cola could trigger over $20 billion in back taxes, interest, and a higher ongoing effective tax rate, while a win would relieve a decade-long liability and offer reassurance to multinationals facing similar IRS scrutiny.
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Trump Poised to Roll Out New Tariffs as He Refunds the Old Ones

Tariff revenue is now flowing out of the US Treasury’s coffers faster than it’s coming in, with nearly $22 billion in unlawfully collected duties reimbursed to importers in May.

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Corporate Tax Exemptions Most Popular Incentive, OECD Data Says (06/18/2026)

Corporate income tax exemptions remain the most popular investment tax incentive instrument across most of the globe, data compiled by the OECD shows.

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