2026

Compliance Burden to Stay High Under Global Minimum Tax Deal

Simplification measures in the OECD’s new global minimum tax rules are unlikely to reduce the compliance burden for companies as they determine their tax liabilities under the new system, tax professionals said.

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Multinationals Seek Safe Harbors, Tax Clarity for Remote Work

Multinationals asked the OECD for more clarity on complex questions around how corporations should be taxed in relation to remote work and a safe harbor for short-term cross-border working.

Here is the OECD consultation document on remote work, along with comments on it.

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Venezuela, Greenland, and the Side-by-Side Package

Herzfeld contrasts early 2026 geopolitical shock tactics with the unusually cooperative breakthrough on the OECD Inclusive Framework on BEPS side-by-side package for pillar 2, framing international tax as a way of multilateralism. Herzfeld explains that the package is not just “GILTI equivalence” optics, as it prioritizes simplification safe harbors, extends the CbCR safe harbor, and then creates an elective side-by-side safe harbor that effectively shields U.S. groups from the IIR and UTPR. But the U.S. sovereignty is partly “priced” through ongoing review and continued QDMTT-driven compliance and calculation burdens, and smaller economies may face tighter constraints on the incentives they relied on to attract investment. Herzfeld questions why it took years and near retaliation to reach a workable accommodation and warns that the deal’s durability depends on politics, administrative complexity, and how the monitoring regime evolves.

Europe’s Own Trade Barriers Are Worse Than Trump’s, ECB Finds

Trade frictions across the European Union are more onerous than the highest tariff US President Donald Trump threatened to slap on the bloc last year, according to research by the European Central Bank.

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OECD Pressed for More Guidance on Permanent Establishment Rules

Companies need additional guidance on the impacts of remote work on corporate taxes and the creation of taxable permanent establishments, practitioners told the OECD in comments as part of the group’s global workforce mobility project.

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OECD Makes Case for Developing Countries to Adopt Minimum Tax

Developing countries will want to adopt the global minimum tax because they will collect revenue, and further work is being done to make the levy more administrable, a top OECD official said.

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US’ Global Minimum Tax Carveout Is an Illusion of Sovereignty

Supporters of the OECD’s new Pillar Two “side-by-side” agreement—which carves the US out of the global minimum tax—claim the deal protects US tax sovereignty and preserves Congress’ authority over domestic tax law.

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EU Puts Revised Global Minimum Tax Agreement Into Effect

The European Commission published changes to the bloc’s minimum tax law in its official journal, putting into legal effect the revised the agreement reached by countries at the OECD last week.

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Deloitte Urges New Minimum Tax Guidance From Singapore

Singapore should use an upcoming budget to issue new guidance on the global minimum tax and expand an investment credit launched in the tax’s wake, Deloitte said.

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OECD Focused on MAP for Transfer Pricing in Substance Cases

Examines a new OECD initiative aimed at ensuring mutual agreement procedures remain available for adjustments that are substantively transfer pricing–related but not formally characterized as such.

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