2026

Transfer pricing, which is how companies price transactions between affiliates, underwent colossal changes in the US over the past year, and the new year promises to be at least as tumultuous.

The UK will amend its global minimum tax law to apply recent changes to the OECD-led framework from January 2026, the country’s tax minister said.

Discusses proposals from Dutch tax advisers on incorporating the EU’s Unshell initiative into DAC6 reporting obligations through the creation of a new disclosure hallmark.

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Mindy Herzfeld reviews major international tax developments from 2025,  including disruptions to the OECD’s two-pillar project, evolving tariff policy, and legislative, regulatory, and judicial uncertainty, and assesses what these trends suggest for the international tax agenda in 2026.

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Examines the European Commission’s plan to recalibrate its tax agenda in 2026 by prioritizing narrower, targeted initiatives over broad, comprehensive reforms.

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Covers a planned legal challenge to Belgian legislation authorizing tax authorities to use artificial intelligence to mine financial data, focusing on privacy and proportionality concerns.

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Examines unresolved conceptual and practical issues surrounding the treatment of goodwill in transfer pricing analyses and disputes

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The Treasury Department announced an agreement with OECD Inclusive Framework members confirming that certain U.S.-headquartered multinational groups will be exempt from key elements of the Pillar Two global minimum tax regime. The announcement reflects ongoing efforts to align the Pillar Two framework with existing U.S. tax rules, including the treatment of GILTI. Treasury emphasized that the agreement preserves U.S. taxing rights while reducing the risk of double taxation for U.S. multinationals operating abroad. The development has important implications for the future interaction between U.S. international tax law and the OECD’s global minimum tax project.

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This press release announces that the 147 members of the OECD/G20 Inclusive Framework have agreed on key elements of a package advancing the coordinated operation of the global minimum tax, which includes the side-by-side approach reflected in the Tax Notes article

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US business groups and lawmakers welcomed an agreement reached by over 140 countries at the OECD that would exempt American companies from major parts of the global minimum tax framework.