2026
US Companies Say Dutch Treaty Proposal Would Increase Tax Burden
Business groups are pushing back against a Netherlands proposal to accept more withholding taxes in treaties with developing countries, saying it would raise taxes for multinationals and dampen investment. The debate is reflected in submissions by the [U.S. Council for International Business (USCIB)], the [Information Technology Industry Council (ITI)], and the [National Foreign Trade Council (NFTC)], together with the Dutch Ministry of Finance's consultation document.
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Using the U.N. Tax Convention to Prevent Economic Retaliation
The South Centre, an intergovernmental think tank of developing countries, has proposed that the UN framework convention on international tax cooperation give its signatories a mechanism to respond collectively to economic threats and coercive measures against countries that tax cross-border services.
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U.N., OECD Say They Complement and Don’t Compete on Tax
t the International Fiscal Association congress on October 21, John Peterson of the OECD and Chetan Rao of the UN Department of Economic and Social Affairs said the two bodies have distinct mandates and complement each other’s tax work. Peterson said the OECD’s narrower mandate suits some tasks and not others, and that the OECD has managed overlap with the UN well, including by staying aligned on transfer pricing.
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Countries Gear Up to Resume Digital Taxation Talks at OECD
John Peterson of the OECD said at the International Fiscal Association congress on October 21 that the inclusive framework will soon resume talks on taxing the digital economy through a ‘constructive dialogue’ that may set Amount A aside and revisit the questions raised in its 2018 interim report in light of changed business models.
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OECD to Revisit Taxing Digital Economy With New Plan (1)
The Organization for Economic Cooperation and Development will explore new alternatives to taxing the digital economy, moving away from a previously agreed framework, a top tax official said.
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OECD Global Mobility Work to Raise Business Restructuring Issue
Saranee de Silva of the OECD’s transfer pricing unit said at the International Fiscal Association congress on October 19 that the OECD’s global mobility work is examining whether the physical relocation of a higher-value or risk-related function triggers a business restructuring, a question it has not yet addressed. She said jurisdictions have also proposed business restructuring as a topic for the working party’s review of the transfer pricing guidelines, which is not yet open to business, and that the discussion matters because the issue has received little attention since the BEPS project.
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U.S. Notes Concerns Over Australia Software Ruling, MAP Access
Rebecca Burch, the US Treasury’s deputy assistant secretary for international tax affairs, said at the International Fiscal Association congress on October 19 that, despite the Australian Taxation Office’s stated openness to the mutual agreement procedure, Treasury hears growing concern that the office is avoiding that procedure and will apply its new ruling on software and intellectual property royalties aggressively, causing double taxation. The ruling, TR 2026/2, was issued on 4 September 2026, finalising a 2024 draft that had been held back while the High Court of Australia decided PepsiCo, in which it held in August 2025 that PepsiCo’s Australian entity was not liable for withholding tax on royalties said to be embedded in its bottling agreements.
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