Fresh Ideas Emerge for New EU Budget Levies

This article examines Pakistan’s statutory regime for taxing cross-border digital transactions and its interaction with international tax rules. It focuses on the coexistence of Pakistan’s digital tax measures with its double tax agreements, including questions involving permanent establishment, business nexus, duplication across multiple legislative instruments, and enforcement by domestic tax authorities.

Citation: Khan Niazi, Shafi Ullah, Statutory Measures Adopted by Pakistan to Tax Cross-Border Digital Transactions: Inconsistencies and Inadequacies? (March 31, 2026). Statute Law Review, Volume 47, No. 2. pp. 1-19.

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This paper examines the tax treatment of crypto-assets in the European Union and compares the EU approach with developments in the United Kingdom, United States, Singapore, and the UAE. It focuses on the gap between harmonised financial regulation under MiCA and fragmented tax rules across jurisdictions, with particular attention to DAC8, the OECD Crypto-Asset Reporting Framework, classification problems, enforcement gaps intensified by anonymity and decentralised finance, and divergent implementation rules.

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This article examines how international tax treaties allocate taxing rights over dependent employment income in an era of remote work, frontier work, and digital mobility. Focusing on Article 15 of the OECD Model Tax Convention, the author argues that existing rules are no longer adequate for cross-border telework and proposes a reform based on the Ottawa Taxation Framework and labor neutrality principles.

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This paper examines the incidence of digital services taxes imposed on large digital platforms, focusing on whether the burden is borne by platforms or passed on to advertisers through higher advertising prices. Using Google Ads data across 29 European countries, the authors find that advertisers bear a substantial share of the tax burden, with evidence of near-complete pass-through through higher effective costs per click.

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This volume provides a comparative overview of major transaction-based taxes, including VAT/GST, customs duties, tariffs, excise duties, environmental taxes, digital services taxes, and taxes on capital transfers. It situates indirect taxation in a global context by drawing on examples from multiple jurisdictions and referencing OECD, IMF, UN, and EU standards, with attention to the challenges posed by digitalization, globalization, and environmental policy.

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This paper examines the incidence of digital service taxes, focusing on how such taxes affect prices and tax burdens in platform markets such as Amazon. By studying who ultimately bears the cost of taxes imposed on large digital platforms, the paper contributes to debates over the economic effects of unilateral digital tax measures.

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This paper examines whether Canada’s tax sovereignty has narrowed as domestic legislation increasingly responds to international tax coordination and cross-border tax challenges. It uses changes to the Income Tax Act to consider how far national tax autonomy may be constrained by external pressures, coordinated standards, and the need to respond to international tax planning.

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This article examines the historical origins of retaliatory taxation in the United States and its relationship to the development of America’s first tax treaty. Cui uses newly examined historical materials to show how retaliatory tax measures and treaty-based cooperation emerged as competing approaches to international tax conflict.

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Jay Butler, Global Tax for Repair, 59 NYU J. Int’l Law & Pol. ____ (forthcoming 2027).

This article examines whether the OECD’s Global Minimum Tax can serve as a vehicle for cross-border reparations and corrective justice. Butler argues that companies within the GMT’s scope may use their discretion over where minimum tax is paid to respond to historical harms, including reparations for slavery. The article reframes global tax planning as a question not only of revenue allocation, but also of redistribution, corporate social responsibility, and repair.

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This submission to Treasury and the IRS recommends priority guidance projects in several international tax areas for the 2026–2027 Priority Guidance Plan. The comments focus on profit-shifting structures and call for updated guidance on effectively connected income, income sourcing, entity classification, subpart F, cost sharing agreements, transfer pricing, and treaty abuse. Kadet argues that clearer and more modernized rules would help the IRS address shifted profits more effectively and reduce uncertainty for taxpayers.

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