2026
Taxing the Model Owners: A Flag State Regime for Artificial Intelligence
The authors propose that each large artificial intelligence (AI) foundation model receive a tax situs by registration, following the law of the flag, with the residual return on the model’s weights divided among the jurisdictions that supply its compute, its control, and its users. Existing approaches reach the hyperscalers and the deployers but stop short of the model owners, such as OpenAI and Anthropic, with whom the residual stays. The authors argue that nexus, sourcing, and pricing rules each fail because the weights have no usable location, so the model owner can book the residual wherever it chooses.
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EU Says Ireland, Hungary Unfair to Other Nations’ Bonds on Tax (10/02/2026)
The European Commission warned Ireland and Hungary to end what it alleges is discriminatory tax treatment of other EU and European Economic Area countries’ bonds.
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American Territories Closer to Removal From EU Tax Blacklist
The European Commission is considering removing American Samoa, Guam, and the US Virgin Islands from the EU’s list of tax havens, according to three people familiar with the discussions. The territories have been on the EU’s blacklist for more than eight years. During that time, the US has worked with the territories to remove them from the list, but recent talks indicate that a breakthrough on tax transparency is close.
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Too Early to Judge Global Minimum Tax’s Effectiveness, EU Says (10/01/2026)
The European Commission said on October 1, 2026, it can’t yet determine whether the global minimum tax is fit for purpose, because corporate data collection is in its early days.
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EU Calls on Five Countries to Stiffen Penalties on Tax Reporting
The European Commission warned five EU countries Thursday that their penalties aren’t stringent enough for multinational companies and wealthy individuals who fail to meet their obligations to disclose tax information to authorities.
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Model Tax Convention on Income and on Capital 2025 (Full Version)
The eleventh edition of the full OECD Model Tax Convention is a key reference used by OECD members and non-members for negotiating, applying, and interpreting bilateral income and capital tax treaties. The Model addresses tax-related barriers to cross-border trade and investment, tax evasion and avoidance, and international double taxation. This edition contains the Model as it read on November 18, 2025, including its Articles, Commentaries, non-member economies’ positions, the Recommendation of the OECD Council, historical notes, and background reports.
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Advancing the Implementation of the EU Carbon Border Adjustment Mechanism
This report provides practical guidance for implementing the EU Carbon Border Adjustment Mechanism in Romania and other EU Member States, focusing on operational arrangements, customs administration, governance, and coordination among competent authorities. CBAM applies a carbon price to selected imported goods corresponding to that faced by domestic producers under the EU Emissions Trading System, with the aim of mitigating carbon leakage. The report examines implementation challenges arising during the definitive period that began on January 1, 2026, including annual reporting, third-party verification, CBAM certificates, customs integration, risk management, and measures to prevent circumvention.
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UK Tax Authority Contacts Multinationals Over Profit Diversion (09/30/2026)
The UK tax authority will launch investigations into multinational companies that fail to engage with its transfer pricing compliance facility, as it steps up efforts to crack down on profit diversion.
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Swiss Lawmakers Want to Tax Firms When They Hire Foreign Workers
Switzerland’s upper house backed an immigration tax on companies hiring foreign workers, a controversial proposal in a country where many multinationals say they need to have easy access to international talent.
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EU Debates Locking US Companies Out of Corporate Tax Streamline
The European Commission is shutting American businesses out of major perks in its pro-business tax legislation because of concern they could use the provisions to get out of paying taxes, according to confidential documents obtained by Bloomberg.
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