2026

Negotiations for a United Nations tax agreement that resume on August 3, 2026, in New York could set a new high-water mark for a decades-long effort to rewire the global system of bilateral tax treaties.

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This announcement reports on a regional meeting in Georgetown, Guyana, attended by 29 officials from 15 Caribbean jurisdictions to discuss tax and development priorities. The dialogue covered the Global Minimum Tax and tax incentives, taxation of the tourism sector, tax-administration modernization, and international tax-transparency standards. Participants emphasized regional cooperation, domestic resource mobilization, and capacity building as tools for implementing international tax standards and responding to the Caribbean’s economic, climate-related, and sustainable-development challenges.

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Working Party 6 is running a parallel project under article 25 of the OECD model tax convention to preserve MAP access when countries use domestic law to enforce the benefits test and disallow intercompany services deductions, Manuel de los Santos of the OECD Centre for Tax Policy and Administration said July 30 at the NABE transfer pricing symposium — a problem the Chapter VII revisions themselves can't fix because the guidelines don't address deductibility. He said the OECD hasn't yet struck the right balance on the discussion paper's proposed list of contemporaneous evidence, which drew stakeholder objections, and that no one on the working party wants the "reasonably expected" benefit standard to invite hindsight evaluation.

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The European Commission may need to revisit its treatment of tax incentives under the EU Foreign Subsidies Regulation, according to a July 28 study for the Directorate-General of Competition reviewing enforcement in acquisitions notified between October 2023 and June 2025. It found the commission often declined to rule explicitly on whether tax measures were foreign subsidies and lacked information to complete its three-step specificity analysis, and suggests relaxing the specificity conditions since sector-specific tax breaks confer a benefit almost by definition.

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Goulder examines the deteriorating state of U.S. trade relations following the July 24 expiration of section 122 tariffs, arguing that the administration's replacement measures — section 301 tariffs on some 80 countries, an unprecedented invocation of Smoot-Hawley's section 338 against $20 billion in Canadian goods, and politically tinged tariffs on Brazil — cast the United States, not its trading partners, as the primary offender against the USMCA.

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Public country-by-country reporting data will be of limited use in gauging the effects of the global minimum tax side-by-side package because top-up tax isn't reported separately and the financial account data underlying CbC reporting differs from the GLOBE tax base, Manal Corwin of the OECD Centre for Tax Policy and Administration said July 29 during a Tax Foundation webinar. She also noted the two regimes run on different timelines, with OECD corporate tax statistics la

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Canada intends to eliminate the base contribution requirement on foreign streaming services and replace it with government funding, the attorney general's office told the Federal Court of Appeal in a July 17 letter made public July 28, responding to a suit by the Motion Picture Association — Canada. The move goes beyond the June 3 directive that the CRTC review its May 21 decision raising contributions to 15 percent of annual revenue, scrapping the 5 percent base contribution imposed under the Online Streaming Act as well — which Michael Geist of the University of Ottawa says leaves the entire framework built since 2024 dead, with taxpayers covering the costs.

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The authors examine how data centers are reshaping international taxation by tying an increasing share of corporate value creation to immobile infrastructure. They consider the implications for taxing rights, sourcing, and future corporate tax reform.

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Hong Kong's government opened a consultation July 27 on tiered tax incentives for corporate treasury centers under the action plan it announced June 9, proposing to let CTCs defer deductions for interest paid to related foreign companies until the recipient becomes taxable, to widen the range of corporations eligible for interest deductions, and to clarify the substantial activity requirement and intragroup financing benchmark. A second tier would add a preapproval mechanism granting further benefits over a five-year validity period. Comments are due September 4, with administrative clarifications expected later this year and legislative amendments in the first half of 2027.

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The Disclosure of Tax Havens and Offshoring Act, reintroduced on July 16, would direct the Securities and Exchange Commission to require large multinational issuers to disclose country-by-country financial and tax information. If enacted, the bill would impose substantial compliance burdens and increase reputational and business risks for multinationals.

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