2026
From spare rooms to second-hand sales: How tax reporting continues to adapt to the platform economy
This article discusses proposed revisions to the OECD Model Reporting Rules for Digital Platforms, which establish a common framework for collecting, reporting, and exchanging information about income earned by platform sellers. The proposed changes include removing the transaction-count threshold and increasing the reporting threshold for low-value sellers from EUR 2,000 to EUR 3,000, clarifying platform and operator definitions, reducing duplicate reporting, and improving identification of the persons ultimately receiving platform income. The revisions aim to strengthen international tax transparency while reducing unnecessary compliance burdens.
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Safe Harbor and Indonesia’s Next Global Minimum Tax Test
The author argues that Indonesia’s 2025 global minimum tax regulation, PMK 136/2024, which introduced the income inclusion rule, a domestic minimum top-up tax, the undertaxed profits rule, and a set of safe harbours, has been overtaken by the side-by-side package agreed in January 2026. That package added a permanent simplified ETR safe harbour, extended the transitional country-by-country reporting safe harbour, and gave special treatment to qualifying substance-based tax incentives. The author contends that Indonesia’s task is to shape its domestic policy so that incentives tied to real economic activity keep their value while the regime stays aligned with the evolving rules.
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Chapter 3: Intangible Yet Real: Spillovers from Corporate Income Taxation
Chapter 3 of the IMF’s October 2026 World Economic Outlook examines how multinational corporations, intangible assets, and the globalization of production have changed the cross-border effects of corporate income tax policies. The IMF finds that stronger anti-avoidance rules have weakened incentives for multinational profit shifting, while real investment has become more sensitive to differences in corporate tax rates across jurisdictions. Debt-financed corporate tax cuts can generate negative spillovers abroad in the short term, while longer-term spillovers may become positive through cross-border knowledge transfers; lower corporate tax revenues can also constrain domestic public investment, particularly in emerging market and developing economies.
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BRICS Is Expanding Its International Tax Ambitions
The BRICS bloc, including all countries and partner countries, is increasingly strategizing international tax coordination and cooperation. In multilateral tax fora, BRICS countries have taken leadership roles within both OECD and U.N. negotiations. BRICS tax authorities have announced that they’ve established two new working groups — one on international taxation and transfer pricing, the other on revenue statistics. India will lead both working groups.
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The True Nature and Policy Rationale of Digital Services Taxes
In response to an article by Peter A. Barnes and H. David Rosenbloom (Tax Notes Int’l, Sept. 7, 2026, p. 1591.), the authors argue that DSTs represent a sui generis category: levies designed to capture value that is extracted from a jurisdiction through the systematic collection, exploitation, and monetization of users’ data and contributions. They are neither an income tax on the supplier nor a consumption tax on the consumer.
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Pillar 2 Minimum Tax Fight Hits Procedural Roadblock in Germany
In its June 24 decision in 3 K 2419/25, published September 25, the Tax Court of Cologne dismissed the taxpayer’s petition against the return filing requirements under Germany's Minimum Tax Act as premature, ruling that the taxpayer did not have standing to challenge its obligations under the act before it submitted a return. The court sidestepped the taxpayer’s arguments that the EU directive underlying the country's pillar 2 regime is invalid.
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IMF Says Antiavoidance Rules Limit Multinational Profit Shifting
In an analytical chapter from its forthcoming World Economic Outlook report, the IMF found that a global increase in antiavoidance rules has changed tax competition to focus less on profits and more on real investments and productive activity. Tax competition has also moved away from simply cutting corporate income tax headline rates.
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Before Pillar 2: Ghana’s Subject-to-Tax Treaty Rules
The subject-to-tax rule, adopted in model form by the OECD and the United Nations after the BEPS project, lets a source state tax certain intragroup payments that a treaty assigns to the residence state when the payee’s state taxes them below 9 per cent or an agreed minimum rate. The article asks whether five of Ghana’s 14 tax treaties, concluded long before the model rules, already contain a comparable rule, focusing on article 23 of the Denmark-Ghana treaty and on what the model rules mean for Ghana’s treaty network.
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