2026

The OECD released a draft proposing a substantial revision of its transfer pricing guidelines on intro group services, the first major overhaul since 2015. While it does not offer the arm’s-length principle, it provides more guidance on how taxpayers and tax administrations should analyze those services and provides practical examples in the annex. 

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The EU is drafting a massive tax package that could save companies about €5.3 billion a year by completely scrapping minimum holding requirements for withholding tax exemptions on intra-EU dividends, interest, and royalties. It also simplifies cross-border dispute resolutions, though some member states might fight it since it could erode their local tax revenues.

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As global minimum tax compliance goes live, jurisdictions are rapidly rolling out critical administrative updates. Belgium has officially finalized its 2024 QDMTT return template and extended key filing deadlines, while Australia, Ireland, Italy, Malaysia, Portugal, South Africa, and Sweden have dropped urgent guidance covering account setups, GIR filing portals, safe harbors, and penalty relief.

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The European Commission is set to transform the Anti-Tax Avoidance Directive (ATAD) into a broader competitiveness framework featuring a new harmonized R&D allowance. The leaked draft omnibus proposal also aims to slash corporate compliance costs by introducing mandatory interest limitation relief and a sweeping Controlled Foreign Company (CFC) rule exemption for Pillar 2 groups and SMEs.

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Malherbe and Strauven examine the conditions that have prompted a newly proposed Belgian digital services tax.

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Herzfeld examines the EC’s new foreign subsidiaries regulation, including how the commission has wielded the regulation as part of its broader state aid efforts and implication for U.S. companies.

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The EC has started evaluating alternatives for the EU budget such as a digital services tax. The DST would target digital services, online gambling, and cryptoassets and could raise €5 billion annually.

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In the final installment of a four-part series, Gribinski offers examples demonstrating how the proposes autonomous AI nexus system would work.

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In the first installment of a three-part series, Levine explores the reasons behind Europe’s struggles to foster world-class technology companies despite its world-class scientists and engineers.

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Ten EU countries are aiming to sign an agreement by the end of the year to create a cross-border tax dispute resolution commission that would improve the speed and efficiency of mutual agreement procedures.

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