2026

Malaysia Investment Incentives Shift From a Primary Focus on Tax

Malaysia will launch the first phase of its new incentive framework on March 1, reframing investment inducements around measurable economic substance and national benefit rather than traditional profit-based tax holidays. The framework is explicitly designed for a pillar 2 environment, replacing blunt tax incentives with outcome-based evaluation through a National Investment Aspirations scorecard tied to jobs, supply chains, and sustainability. Companies must choose between a long-term special tax rate regime or an investment tax allowance, signaling a structural shift toward aligning incentives with global minimum tax constraints rather than competing through headline rate reductions.

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Transfer Pricing in Quicksand in 2026

This article explores how technological change, regulatory uncertainty, and enforcement pressures are reshaping global transfer pricing risk heading into 2026.

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Poland to Propose a Digital Services Tax of Up to 3 Percent

Poland says it will draft legislation for a digital services tax of up to 3% aimed at large groups, framing the measure as a competitiveness and “digital sovereignty” response to cross border platform activity that is monetized in Poland but taxed elsewhere. The proposal targets revenues from targeted advertising, multilateral platform intermediation, and monetization of user derived data, while carving out streaming content, communications and payments, and direct online sellers that are not intermediaries. The tax would apply only above both a global size threshold and a Poland revenue threshold, and would be reduced by Polish corporate income tax, which is a design choice meant to blunt double taxation and treaty friction but also raises base definition and crediting questions.  

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Can the EU’s Foreign Subsidy Regulation ‘Discipline’ U.S. Subsidies?

The authors examine whether the EU’s Foreign Subsidies Regulation can be used as a de facto trade defense tool against U.S. industrial policy subsidies, including tax measures such as the revamped FDDEI regime. They argue that the FSR fills a gap left by the paralysis of WTO dispute settlement by allowing the European Commission to target foreign subsidies that distort the internal market through procurement restrictions, merger controls, and ex officio investigations. Tax incentives structured as forgone revenue may qualify as foreign subsidies under the FSR, potentially exposing U.S. multinationals to EU enforcement even where WTO remedies are unavailable. The piece frames the FSR as both a legal innovation and a politically contingent instrument in an era of post-globalization industrial policy and escalating transatlantic trade tensions.

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Can the OECD Reshape Cross-Border Work Taxation in a Digital Age?

Despite the growing complexity of border crossings and regulatory requirements, the need for workforce mobility—and its benefits—remains as vital as ever. Organizations continue to rely on international collaboration and flexible talent exchange as key drivers of growth, innovation, and competitive advantage.

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U.N. Protocol Would Address Disputes Under Existing Tax Treaties

A draft protocol on dispute prevention and resolution under the U.N. tax cooperation framework would focus on resolving cross-border tax disputes between states arising under existing bilateral or multilateral tax treaties, while also exploring optional mechanisms for no-treaty situations, expanded MAP tools, coordinated APAs, and a possible U.N.-led transfer pricing task force. 

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‘Side by Side’ Global Tax Deal Tests Pillar Two’s Staying Power

The OECD’s long-awaited side-by-side package is a pragmatic attempt to preserve the global minimum tax architecture while accommodating the unique position of US multinationals. That pragmatism, however, comes with limits.

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EU Sees Reopened OECD Digital Tax Talks Departing From Old Plan

There is “still willingness from all jurisdictions” at the OECD to restart stalled negotiations for a global tax on digital services, but the talks will likely deviate from the framework’s current construction, according to a senior EU official.

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UN Panel Plans Task Force on Access to Transfer Pricing Info

United Nations negotiators working on a new global tax treaty plan to establish a task force to explore and identify practical options for improving countries’ access to transfer pricing information.

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Global Tax Deal Sparks Fear US Law Will Be Tougher to Change (1)

A global agreement to exempt US multinationals from key parts of the 15% global minimum tax is raising concerns that its rules may tie the hands of Congress to make corporate-friendly changes to the US tax code in the future.

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