2026

EU’s DAC Recast Facilitates Future Pillar 2 Reporting Changes
The European Commission's proposed recast of the EU's administrative cooperation directives would consolidate all DAC rules into a single framework, cut €1.283 billion in compliance costs, and empower the commission to adopt implementing acts to align EU rules with future OECD GLOBE information return updates without requiring unanimous legislative amendments. Key changes include easing DAC6 reporting burdens for pillar 2 in-scope multinationals, raising DAC7 digital platform reporting thresholds, and streamlining DAC4 and DAC9 notification requirements.
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Pillar 2 Reshuffles the Cards of EU Antiabuse Rules
The European Commission's tax simplification omnibus proposes sweeping changes to EU antiabuse rules, including exempting pillar 2 companies from controlled foreign company rules, mandating a €3 million interest deduction threshold, and introducing a full withholding tax exemption on intragroup interest, royalties, and dividends effective 2037. The package also introduces a minimum R&D allowance standard within the ATAD, with the commission citing pillar 2 as justification for rolling back overlapping antiabuse measures that risk creating double taxation.
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Italy Reports DST Surge, Weak Global Minimum Tax Revenue
Italy's Court of Auditors reported that the country's digital services tax generated €637 million in 2025, a 40 percent increase from the prior year, while its first-year global minimum tax revenue came in at just €46 million against a forecast of €381 million. The report also noted continued growth in Italy's flat tax regime for high-net-worth individuals relocating to Italy, with the annual substitute tax now set at €300,000 following successive increases.
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OECD Aware of Issues With Pillar 2 and Investment Treaties
OECD officials and tax experts warned that bilateral investment treaty protections in many countries could complicate or trigger arbitration against states implementing qualified domestic minimum top-up taxes, with one analysis suggesting 90 percent of existing investment treaties could expose such measures to investor challenges. The inclusive framework is working toward a coordinated solution, while multinationals and host countries weigh restructuring investments or renegotiating agreements to avoid disputes.
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AI Has No Place in Global Digital Tax Talks, US Official Says (06/23/2026) Author: Lauren Vella

Artificial intelligence doesn’t belong in the OECD-led discussions about taxing the digital economy, the top US delegate to the organization said on June 23, 2026.

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Fragmented Filings Complicated Access to EU Public CbC Data
A Fair Tax Foundation review of 302 EU public country-by-country reports found that only 58 percent of companies complied solidly with the directive, with some multinationals filing fragmented single-country disclosures rather than consolidated group-wide reports. U.S. companies and the pharmaceutical sector were the worst performers, and advocates flagged the lack of a central repository as a significant barrier to accessibility.
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2025 MAP Paradigm Shift: The GATS Carveout and Amount B
Takahashi explores the 2025 updates to the OECD and U.N. model conventions and explains how the codification of the General Agreement on Trade in Services carveout and the standardization of amount B establishes the mutual agreement procedure as a strategic buffer to limit or reduce geopolitical friction.
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OECD to Release Data on Impact of US Global Tax Carve-Out (1) (06/22/2026)

The OECD plans to release a report in July on the impact of the global minimum tax following a January agreement that carves out US multinationals from key parts of the minimum levy’s framework.

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EP Political Groups Lament Pillar 2 Side-by-Side Deal
MEPs across all major political groups pushed back on the EU's side-by-side package shielding U.S. multinationals from most pillar 2 obligations, warning it creates competitive disadvantages for European businesses and undermines the global minimum tax framework. Several groups also called on the commission to withdraw or overhaul the BEFIT corporate tax harmonization proposal over its incompatibilities with pillar 2.
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U.N. to Issue Deeper Report on Tax Cooperation Progress in 2027
The U.N. and a task force of over 60 international institutions plan to publish a detailed 2027 report tracking countries' progress on the Sevilla Commitment, a 2025 agreement aimed at strengthening tax cooperation and boosting domestic resource mobilization in developing countries. The report will draw on the OECD's global revenue statistics tool to measure progress across commitments including tax transparency, taxation of high-net-worth individuals, and evidence-based tax incentive reform.
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