2026

Lessons From Libya? A Source-Based Tax Regime Without Permanent Establishment

Busefi writes that Libya largely ignores the usual permanent establishment (PE) concept and instead taxes foreign businesses based on a simple source link. For cross-border service providers and investors, PE planning won’t protect you, and the real risk shifts to withholding, counterparty compliance, and messy treaty conflicts with OECD-style PE rules. Busefi notes Libya has strengthened enforcement by removing limitation periods for unpaid tax recovery, creating an effectively open-ended audit window and signaling a broader drift toward source-based taxation for remote/digital services.

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Turkey’s Erdogan Cuts Digital Services Tax Rate

Examines Turkey’s reduction of its digital services tax rate and considers broader implications for digital tax policy and international coordination.

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Inter-Parliamentary Union Proposes to Address Tax Avoidance, Protectionism

Reviews international parliamentary efforts to address multinational tax avoidance and the growing use of protectionist tax measures, examining the Inter-Parliamentary Union’s proposed resolution and its potential role alongside existing global tax coordination initiatives led by the OECD/G20 and the U.N. Tax Committee.

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Those Tax Modelers? So Hot Right Now

Discusses how AI-driven tax modeling and new legislation are reshaping tax administration and compliance globally.

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Dutch Appeals Court Deems Uber Drivers Entrepreneurs

An Amsterdam appeals court ruled that Uber drivers can qualify as entrepreneurs rather than employees, overturning a lower court decision that would have imposed retroactive employment obligations on Uber. The ruling emphasizes individual drivers’ degree of entrepreneurship and leaves enforcement of misclassification rules largely to tax authorities.

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Fresh Ideas Emerge for New EU Budget Levies

The European Parliament is considering new EU own resources that would tax online gambling, speculative real estate investment, and large companies through a turnover-based CORE contribution. The proposals expose significant legal and institutional constraints, including unanimity requirements, subsidiarity limits, especially for gambling, and unresolved questions about where digitally delivered activity should be taxed. Academic analysis warned that CORE could lead to multiple counting within corporate groups and impose tax liabilities that are disconnected from profitability, raising concerns about neutrality, legal characterization, and enforceability. The debate illustrates the persistent tension in EU tax policy between ambitious revenue goals and the structural limits of EU-level taxation.

Malaysia Investment Incentives Shift From a Primary Focus on Tax

Malaysia will launch the first phase of its new incentive framework on March 1, reframing investment inducements around measurable economic substance and national benefit rather than traditional profit-based tax holidays. The framework is explicitly designed for a pillar 2 environment, replacing blunt tax incentives with outcome-based evaluation through a National Investment Aspirations scorecard tied to jobs, supply chains, and sustainability. Companies must choose between a long-term special tax rate regime or an investment tax allowance, signaling a structural shift toward aligning incentives with global minimum tax constraints rather than competing through headline rate reductions.

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Transfer Pricing in Quicksand in 2026

This article explores how technological change, regulatory uncertainty, and enforcement pressures are reshaping global transfer pricing risk heading into 2026.

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Poland to Propose a Digital Services Tax of Up to 3 Percent

Poland says it will draft legislation for a digital services tax of up to 3% aimed at large groups, framing the measure as a competitiveness and “digital sovereignty” response to cross border platform activity that is monetized in Poland but taxed elsewhere. The proposal targets revenues from targeted advertising, multilateral platform intermediation, and monetization of user derived data, while carving out streaming content, communications and payments, and direct online sellers that are not intermediaries. The tax would apply only above both a global size threshold and a Poland revenue threshold, and would be reduced by Polish corporate income tax, which is a design choice meant to blunt double taxation and treaty friction but also raises base definition and crediting questions.  

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Can the EU’s Foreign Subsidy Regulation ‘Discipline’ U.S. Subsidies?

The authors examine whether the EU’s Foreign Subsidies Regulation can be used as a de facto trade defense tool against U.S. industrial policy subsidies, including tax measures such as the revamped FDDEI regime. They argue that the FSR fills a gap left by the paralysis of WTO dispute settlement by allowing the European Commission to target foreign subsidies that distort the internal market through procurement restrictions, merger controls, and ex officio investigations. Tax incentives structured as forgone revenue may qualify as foreign subsidies under the FSR, potentially exposing U.S. multinationals to EU enforcement even where WTO remedies are unavailable. The piece frames the FSR as both a legal innovation and a politically contingent instrument in an era of post-globalization industrial policy and escalating transatlantic trade tensions.

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