2026

The UK should develop targeted tax relief for entrepreneurs who successfully build a high-value business, but only if it is paired with broader capital gains tax reform, a think tank has suggested.

To read the full article, click here (subscription required).

The European Commission is considering a levy on big US companies which would secure more income from tech firms such as Apple, Meta and Google, the Financial Times reports, citing six unidentified officials with knowledge of the discussions.

To read the full article, click here (subscription required).

European Parliament lawmakers have called on the OECD and European Commission to evaluate the revised global minimum tax arrangement after US companies were exempted from certain provisions of the levy.

To read the full article, click here (subscription required).

The OECD is assessing requests from Brazil and Colombia, the only two jurisdictions to apply for recognition under the side-by-side package. OECD official John Peterson said Brazil has ‘quite a strong case’ because it has a QDMTT and broad CFC rules, while Colombia’s eligibility depends on whether multinationals there reach a 15 per cent effective rate overall; the inclusive framework has set no deadline for a decision.

Click here for the full article. 

The author argues that Pillar Two is producing a ‘K-shaped’ outcome: jurisdictions that stayed out, mainly the United States and China, sit on the upper arm, while adopters, chiefly EU member states, pay implementation and enforcement costs for revenue well short of projections. Ironically, the main winners are the low-tax hubs that collect top-up tax through QDMTTs, the very jurisdictions the regime was designed to penalize. Her conclusion is that a ‘global’ minimum tax that is not global will neither deliver the promised revenue nor answer the larger threat to European competitiveness.

Click here for full article

Driessen argues that Pillar Two and the Internal Revenue Code as they stood at the end of the Biden administration served the fiscal and trade sovereignty of the United States better than the side-by-side agreement does. He contends that critics of the Biden negotiators define sovereignty too narrowly and are ‘too reverential’ towards a tax legacy that the 2017 Tax Cuts and Jobs Act had already made ‘mostly moot’ for Pillar Two. He treats foreign tax credit blending as informal tax sparing and argues that Congress met its own 2017 revenue needs by scoring the Act’s international provisions on the assumption that foreign governments would not respond.

Click here for the full article

In a rebuttal to a recent article by Peter A. Barnes and H. David Rosenbloom, Khetan counters their claim that a digital services tax is a consumption tax by another name, citing India as a test case. Khetan argues that India’s equalization levy was built as a substitute for income tax and operated alongside a VAT on digital supplies, challenging the claim that when India imposed equalisation levies it was imposing a consumption tax.

Click here for the full article. 

European Parliament estimates show that a 5 per cent EU digital services tax extended to streaming, cloud hosting, and data processing could raise about €25 billion a year for the EU budget, against the Commission’s estimate of €5 billion for a 3 per cent tax on the narrower base of its 2018 proposal. The Parliament also revises upwards the Commission’s estimates for an online gambling levy, to €2.9 billion a year, and for a capital gains tax on cryptoassets, to €3 billion a year.

Click here for the full article. 

Argentina’s Revenue and Customs Control Agency has replaced much of its 2020 transfer pricing regime with General Resolution 5903/2026, which draws on the OECD guidelines and generally applies to fiscal years beginning on or after 1 October 2026. Foreign affiliates may now serve as tested parties in limited cases, qualifying low-value services may be priced at a 5 per cent mark-up without a comparability analysis, and taxpayer-initiated downward adjustments are barred outside mutual agreement procedures. Documentation thresholds rise substantially and will be indexed to inflation from 2028.

Click here for the full article. 

The author argues that the OECD Transfer Pricing Guidelines give no clear guidance on which group entity controls a risk once agentic AI has fully replaced the employees who managed it. He finds none of three allocations satisfactory, to the entity that employed those staff, to the entity that built the AI, or to the AI itself, and he suggests that control may pass to managers who oversee the risk indirectly. He also finds the guidelines unclear on whether the change is a business restructuring that requires arm’s length compensation.

Click here for the full article.