2026

A higher share of non-US tech companies paid the UK’s digital services tax in 2025-26, even as the levy remains a flash point in trade tensions between Washington and London.

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The Treasury Department and the IRS moved Friday to address concerns that sovereign-wealth funds and other foreign-government investors in the US could be penalized by new regulations on when their US investment income is exempt from US taxation.

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The European Commission is proposing a raft of exemptions from certain taxes and rules to headline the bloc’s corporate tax reform aimed at making it easier to do business.

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Since the beginning of 2025, the Trump administration withdrew from a global effort to curb offshore tax-dodging by multinational companies. As a result, U.S. companies skirted at least $40 billion in taxes since then to schemes in places like Malta, Bermuda and Cyprus.

Following the Trump administration withdrawal from global effort to curb offshore tax-dodging by multinational companies since the beginning of 2025, U.S. multinationals have circumvented an estimated $40 billion in taxes in places like Malta, Bermuda and Cyprus.

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Sarfo describes the plans of the new head of the OECD’s Global Forum on Tax Transparency, Maria José Garde, which include implementation of the Crypto-Asset Reporting Framework (CARF) and expanding transparency into real estate, and exploring how AI can safely help tax administrations analyze massive volumes of exchanged financial data.

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The GLOBE consolidated commentary was updated on May 28 and builds on previous version issues in May 2025. Important elements of this package include the side-by-side safe harbor, the ultimate parent entity (UPE) safe harbor, the simplified effective tax safe harbor, the substance-based tax incentive safe harbor, and the one-year extension of the country-by-country reporting safe harbor.

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Panama’s National Assembly approved a 15% tax on the passive income of locally domiciled multinational entities that fail to demonstrate real economic activity. The bill also modernizes Panama’s concept of permanent establishment in accordance with international standards, introduces an anti-abuse clause, and reinforces guarantees regarding the confidentiality and protection of tax information. Panama hopes that this will remove it from the EU’s grey lists of noncooperative tax jurisdictions. 

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Several non-OECD countries believe the U.N. tax convention contains critical gaps in its approach to tackling harmful tax policies and push for developing a fairer international tax system to address these harmful tax practices. Some leaders believe that progress on the U.N. tax convention have slowed with the exit of the U.S. from U.N. talks. 

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Two Dutch academics see constitutional and state aid problems arising from the EC’s implementation of the side-by-side safe harbor. This safe harbor, which exempts corporate groups from the income inclusion rule and undertaxed profits rule if they are headquartered in a qualifying jurisdiction (U.S. is the only jurisdiction with this status), is believed to allow a non-EU body to write EU law. 

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Gomes examines how pillar 2 has altered tax incentives for multinationals under the effective tax rate model of the global anti-base-erosion rules.

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