2026
New and Not-So-New Ideas in the Global Search for Revenue
Budget pressure is driving governments to propose new taxes. In Europe, the Commission is considering a levy on all large companies that would reach US tech groups without naming them, Poland and Portugal have adopted energy windfall taxes, Hungary has proposed a wealth tax, and the United Kingdom is weighing a bank windfall tax. In the United States, states are considering wealth taxes and repealing data centre incentives, and the Treasury has warned that tax-motivated investment fund strategies may fail under existing anti-avoidance doctrines; China has begun taxing income from offshore trusts by administrative announcement. The author concludes that, whether or not these measures are enacted, they show governments everywhere searching for revenue.
Click here for the full article.
Country-by‑Country Reporting – Compilation of 2026 Peer Review Reports
This report reviews jurisdictions’ implementation of the Country-by-Country Reporting minimum standard under BEPS Action 13. It assesses the domestic legal and administrative frameworks for multinational enterprise reporting, the international exchange of CbC reports between tax administrations, and the implementation of relevant safeguards. The compilation identifies progress and outstanding recommendations across participating jurisdictions, providing an overview of the operation of the CbCR framework.
To read the full article, click here.
EU Court Clarifies Right to Tax Dividends in Abusive Structures (10/16/2026)
EU countries may levy withholding tax on dividends paid to a parent company in another EU country if the parent—even while carrying on genuine economic activity—participates in an abusive chain of transactions, the Court of Justice has ruled.
To read the full article, click here (subscription required).
EP Draft Removes DAC6 Carveout for Pillar 2 Firms
The Commission’s proposed recast of the EU directive on administrative cooperation would exempt groups subject to the Pillar Two minimum tax from reporting cross-border tax arrangements under the DAC6 disclosure rules. A draft European Parliament report by MEP Francisco Assis, released on 15 October 2026, would remove that exemption and keep the reporting obligation. Assis argues that experience with the Pillar Two rules is still limited and that dropping the obligation now would deprive tax authorities of information they use to detect aggressive tax planning.
Click here for the full article.
OECD Secretary‑General Tax Report to G20 Finance Ministers and Central Bank Governors (G20 United States, October 2026)
This report provides an update on the OECD’s tax work since April 2026, with particular emphasis on the role of corporate income tax policy in supporting business dynamism and economic growth. It examines how corporate tax rates, compliance costs, loss-offset provisions, financing constraints, and competitive distortions affect business activity. The report also considers how corporate tax policy can contribute to a more dynamic and competitive business environment and identifies areas for further research.
To read the full article, click here.
Tax Relief on Losses Stimulates Business Risk-Taking, OECD Says
Countries that provide limited tax relief to loss-making companies risk stifling entrepreneurial risk-taking and the creation of new businesses, the Organization for Economic Cooperation and Development said.
To read the full article, click here (subscription required).
Developing Countries and the AI Divide in Transfer Pricing Enforcement
The author argues that AI in transfer pricing enforcement is creating an ‘AI divide’ between developed and developing countries, because the administrations that most need AI to offset scarce expertise are the least equipped to deploy it, and the available tools are rarely designed for, trained on, or governed by developing-country conditions. Using Peru’s tax and customs authority, SUNAT, as the main example, the article proposes a governance framework for AI in transfer pricing suited to those conditions.
Click here for the full article.
Google Korea Dodges $115M Tax Bill in Latest Tech Win Against NTS
On 8 October 2026 the Supreme Court of Korea dismissed the National Tax Service’s appeal without stating reasons, leaving in place lower-court rulings that set aside a KRW 154 billion corporate and local income tax assessment on Google Korea. The tax service had treated KRW 975.1 billion of 2016–2018 advertising revenue that Google Korea wired to Google Asia Pacific in Singapore as royalty income, but the courts found the payments were not for the use of information or know-how. Netflix and Meta also won similar disputes with the tax service earlier in 2026.
Click here for the full article.
The California Wealth Tax French Connection
The author, writing against California’s Proposition 40, argues that its 5 per cent tax on residents with assets above $1 billion is economically damaging and rests on a premise that private wealth is an illegitimate diversion from the state. The author traces the measure to French economists, Emmanuel Saez (credited as a co-author), Gabriel Zucman, and Thomas Piketty, and links it to France’s fiscal troubles and to the failure of France’s own wealth tax, which French President Macron scrapped in 2018. Wealth-tax advocates blame the French tax’s failure on its exemptions for business assets and on wealthy taxpayers moving abroad, and that Proposition 40 therefore taxes business ownership and tries to stop Californians from escaping the tax by leaving the state. The author sees the same aim behind the OECD’s BEPS project: to impose European levels of taxation everywhere, so that the United States no longer offers capital a refuge.
Click here for the full article.
Member Companies
