2026

OECD Considers Clarifying Access to MAPs in Model Tax Treaty

The OECD is working on possibly expanding the types of tax adjustments that should be subject to mutual agreement procedures in the organization’s model treaty, an official said.

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EU Tax Chief Advocates Salvaging Work on OECD’s Pillar One

Every option should be exhausted to salvage an OECD project that would reallocate profits of large multinational companies to countries where their sales are made, a top EU official said.

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Companies’ Big Overseas Tax Bills Spur Profit-Shifting Concerns

Some big US-based multinationals are paying more in taxes to other countries than to their own, fueling questions about whether companies are shifting profits abroad to cut their tax bills.

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New OECD Rules Impact Tax Incentive Design for Global Businesses

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting side-by-side package marks a significant evolution of the global minimum tax regime. The package substantially revises the treatment of tax incentives under the global minimum tax. Although developed at the request of the US, its implications extend well beyond.

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Global Tax Redo Leaves Africa Still Vulnerable to Revenue Loss

African nations face a continued risk of losing revenue to developed countries that apply the global minimum tax despite redesigned rules that feature a carve-out for US multinational companies, a group of the continent’s countries argued.

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Nations Uneasy Over UN Playing Bigger Role in Tax Data Exchanges

A large swath of countries pushed back against a proposal that the United Nations play a role in encouraging the exchange of tax information between nations over concerns the move would impose obligations on governments.

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New U.N. Tax Article Could Hit Developing Countries’ Coffers

The article explains the debate over new U.N. Model article 12AA, which would let countries impose gross withholding tax on cross border services even without a permanent establishment. It cites an ICC commissioned Oxford Economics report warning the rule could reduce services trade and investment and ultimately lower developing country revenues, while supporters say it is a simpler way to expand source country taxing rights in a digital economy. For practitioners, the key issues will be how countries define covered services, set rate caps, coordinate credits, and handle disputes if 12AA is adopted.

To read the document, it be can be read here.

African Tax Forum Analyzes OECD's Side-by-Side Package

ATAF’s analysis of the Inclusive Framework’s “side-by-side” package argues that the revisions still leave African countries vulnerable to losing residence-based taxing rights under pillar 2. It stresses that without QDMTTs and incentive reform, locally earned income can be absorbed by other countries through the IIR/UTPR or through new side-by-side outcomes. ATAF supports monitoring features but warns that broadened safe harbors and favorable treatment for certain incentives could erode domestic revenue and undermine tax sovereignty goals. 

For more information, see here. 

AI Makes Tracking Foreign Digital Taxes Harder. Here’s What to Do

The IRS’s final regulations for foreign tax credits for digital taxes cast a broader net than just addressing treatment—they may prevent taxpayers from obtaining foreign tax credits because of artificial intelligence, which enables intellectual property to migrate seamlessly across borders.

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Global Tax Deal Boosts US Allure for Companies Weighing a Move

A growing number of foreign multinationals are exploring whether to relocate their parent companies to the US, with interest spurred in recent weeks by a deal struck at the OECD exempting American businesses from key parts of the 15% global minimum tax.

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