2026
Some Countries Worry About Duplication in U.N. Tax Convention
Global North delegates warned during August 4-5 negotiations on the U.N. framework convention that proposed commitments on harmful tax practices and mutual administrative assistance would duplicate OECD and other international work. The Africa Group, Kenya, and Honduras countered that the talks arose precisely because existing mechanisms have proved neither effective nor inclusive, while Jamaica's Marlene Nembhard Parker cautioned that article 8 appears to shift monitoring from the OECD Forum on Harmful Tax Practices to individual states without a definition or accountability framework.
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Italy Adopts OECD Pillar Package in Sweeping Tax Overhaul
Italy's Council of Ministers gave final approval August 4 to an omnibus decree incorporating the OECD's January 5 side-by-side package into Legislative Decree No. 209/2023, establishing the side-by-side, UPE, and qualified tax incentives safe harbors as elective regimes for fiscal years beginning on or after January 1, 2026, and making covered Italian constituent entities jointly and severally liable for the domestic minimum top-up tax. The decree also introduces a voluntary correction regime for taxpayers renewing the 2026-2027 biennial preventive agreement, extends the VAT deduction window, and rounds out the 2023 tax reform delegation, with separate decrees on the professional tax judiciary, fiscal federalism, and preliminary approval of Italy's VIDA implementation.
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QDMTT, Indirect Coercion, and the Legitimacy Crisis in International Tax Law
Uessler examines whether the qualified domestic minimum top-up tax undermines the legitimacy of domestic tax decisions by materially conditioning states’ fiscal choices, and she argues that although the regime formally preserves fiscal sovereignty, it materially constrains the autonomy of some source states.
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Heinrich Announces Bill to Encourage Domestic Oil Investment
The American Energy Independence and Tax Fairness Act would help “put American energy development on an even playing field with energy development that’s happening in the Middle East or anywhere else,” in part by encouraging oil and gas companies to invest domestically, Sen. Martin Heinrich, D-N.M., said in an August 7 release.
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EU, OECD Countries Demand Treaty Protections in U.N. Tax Talks
EU member states and other OECD countries pressed at the August 3 opening of the fifth negotiating session for the U.N. framework convention to remain high-level and to state expressly that it won't affect parties' rights under existing bilateral, regional, or multilateral agreements absent consent, with Ireland's Matthew Coakley speaking for the bloc and Israel, Japan, Mexico, Norway, South Korea, and the United Kingdom largely agreeing. G77 countries led by the Africa Group and backed by China, India, and Russia defended the draft as written, arguing it tracks the terms of reference — though Belgium, Estonia, and Italy noted that EU states abstained from that vote. Convention talks conclude August 7, with the protocols taken up August 10.
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OECD Countries Push Back on New Nexuses in U.N. Tax Talks
Article 5 of the draft U.N. tax convention lists multiple nexuses for allocating taxing rights — value creation, market location, revenue generation, and user or data location — without establishing any hierarchy or tiebreaker rules among them, the Czech Republic's Lukáš Hrdlička said at the August 3 negotiating session, a concern echoed by 18 other OECD countries warning of double taxation and an undue tilt toward source over residence taxation. India and African states including Algeria, Kenya, and Zambia faulted the same draft from the opposite direction for weakening the fair allocation commitment and dropping economic activities as a nexus, while civil society groups and the G24 pressed for unitary taxation with formulary apportionment.
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Poland Releases Draft Bill for 3 Percent Digital Services Tax
Poland's Ministry of Digital Affairs published draft bill UD385 on July 31, proposing a 3 percent tax from January 1, 2027, on revenues from targeted advertising, intermediation interfaces, and the sale of user data, applying to groups with at least €1 billion in global revenue and more than PLN 25 million in covered Polish revenues. The government projects PLN 31.7 billion (about $8.5 billion) over the next decade. Liability would be reduced by Polish corporate income tax, qualifying R&D costs, and fixed asset expenditures, and the government maintains that as a revenue-based tax it falls outside the scope of double tax treaties.
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Taxing AI Companies Through Equity
Carvalho examines the American A.I. Sovereign Wealth Fund Act, arguing that equity-based taxation could provide public oversight of artificial intelligence companies while raising significant constitutional, governance, and international coordination challenges.
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France Backs Bloc-Wide DST for Next EU Budget, Report Shows
French authorities regard an EU-wide digital services tax as one of the most credible options for a new own resource, according to a July 9 report by Jean-Marie Mizzon, the Senate Finance Committee's special rapporteur on the 2028-2034 EU budget, who urged France to press for a levy modeled on its 2019 national DST — possibly with a broader base or higher rate — while acknowledging it could provoke trade tensions with Washington. Mizzon opposes CORE over its turnover base, arbitrary thresholds, and methodology, and rejects the European Parliament's gambling and cryptoasset levies, warning that France's annual contribution would rise by an estimated €8 billion absent new own resources.
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