Tax News Daily
The latest tax news from around the world, summarised and tagged for tax professionals. Updated twice daily.
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2025 Transfer Pricing Year in Review
KPMG's 2025 Transfer Pricing Year in Review examines how multinational enterprises are navigating a rapidly evolving global transfer pricing landscape shaped by digital disruption and regulatory change. The report covers key developments including the continuing implementation of OECD Pillar Two rules, increased scrutiny from tax authorities worldwide, evolving documentation requirements, and the growing use of data and technology in transfer pricing audits. It highlights trends in advance pricing agreements, dispute resolution mechanisms, and the impact of geopolitical shifts on intercompany pricing strategies. The review serves as a comprehensive reference for tax professionals managing cross-border related-party transactions in an increasingly complex environment.
Avi-Yonah: Taxation and Deglobalization
Professor Reuven Avi-Yonah examines the intersection of taxation and deglobalization, exploring how the retreat from global economic integration is reshaping international tax frameworks. The analysis likely addresses how rising trade barriers, reshoring trends, and geopolitical fragmentation challenge established international tax norms, including transfer pricing rules and the OECD's Pillar Two framework. As supply chains restructure and multinational enterprises reconfigure their operations, tax policy must adapt to a world where cross-border activity is increasingly constrained by non-tax factors. The piece contributes to academic debate on whether current international tax rules remain fit for purpose in a deglobalizing environment.
Analysis of the First Global Pillar Two Filing Season Reveals the Scale of Compliance
An analysis of the first global Pillar Two filing season examines the compliance burden facing multinational enterprises under the OECD's global minimum tax framework. The review highlights the scale of data gathering, jurisdictional complexity, and reporting obligations that tax teams encountered during initial GloBE information return filings. Key findings address the volume of entities in scope, the challenges of safe harbour calculations, and the readiness of tax departments to meet deadlines. The article offers practitioners insight into lessons learned and what to expect in subsequent filing cycles as more countries activate Pillar Two domestic legislation.
DT-05-2026: El Desafío de la Regla de Beneficios Infra-gravados (UTPR) en el marco de los convenios para evitar la doble imposición
This CIAT working paper examines the challenges posed by the Undertaxed Profits Rule (UTPR) under Pillar Two in relation to existing double tax treaties. The UTPR, as a backstop mechanism within the global minimum tax framework, raises complex questions about its compatibility with bilateral tax conventions, particularly regarding non-discrimination clauses and treaty overrides. The paper analyzes how the UTPR interacts with treaty obligations, potential conflicts that may arise when countries implement the rule domestically, and possible approaches to resolving tensions between the global minimum tax rules and existing double taxation agreements.
Noked: “Congress-Proof” International Tax Reforms
This article examines academic proposals for international tax reforms that could be implemented without requiring Congressional approval. The piece explores mechanisms by which the U.S. executive branch or regulatory bodies might advance international tax policy changes—potentially relating to OECD frameworks, Pillar Two, or cross-border tax rules—while bypassing the legislative process. The analysis is relevant to ongoing debates about U.S. engagement with global minimum tax initiatives and the structural constraints facing international tax reform in a divided political environment.
Outdated Transfer Pricing Policies Create New Risks
Outdated transfer pricing policies pose significant risks for multinational companies as global tax environments evolve rapidly. Policies drafted years ago may no longer reflect current business operations, supply chain structures, or regulatory expectations. With increased scrutiny from tax authorities worldwide and the rollout of Pillar Two rules, companies relying on stale intercompany agreements risk audits, penalties, and double taxation. Regular reviews of transfer pricing documentation are essential to ensure alignment with the arm's length principle, updated functional analyses, and current economic conditions. Proactive policy updates help mitigate controversy risk and demonstrate compliance readiness to tax authorities.
How to report Pillar 2 Top-up Taxes
UK government guidance on how multinational enterprises should report Pillar 2 top-up taxes. The guidance covers the administrative and compliance requirements for filing under the global minimum tax framework, including the domestic top-up tax and the multinational top-up tax as implemented in the UK. It provides direction on registration, filing deadlines, and the mechanics of reporting for in-scope groups operating in or through the UK under the OECD's Pillar Two rules, ensuring businesses meet their obligations under the new global minimum effective tax rate regime.
How EPAM managed Pillar Two filings across 27 countries with Orbitax
EPAM, a global technology services company, utilized Orbitax's tax software platform to manage its Pillar Two compliance obligations across 27 countries. The case study highlights how EPAM leveraged Orbitax to streamline data collection, calculation, and filing processes required under the OECD's global minimum tax framework. The solution enabled EPAM to handle the complexity of Pillar Two reporting at scale, ensuring accurate GloBE computations and timely filings across multiple jurisdictions. The case demonstrates the growing role of specialized tax technology in helping multinational enterprises navigate Pillar Two compliance requirements efficiently.
France Pushes Back Deadline For Minimum Tax Returns
France has extended the filing deadline for returns related to the global minimum tax, providing companies additional time to comply with Pillar Two reporting obligations. The delay reflects the administrative complexity businesses face in gathering and processing the data required under the OECD's global minimum tax framework. France's move follows similar deadline extensions granted in other jurisdictions and signals ongoing implementation challenges for the 15% global minimum tax regime. The extension offers multinational enterprises operating in France more breathing room to meet their qualified domestic minimum top-up tax and top-up tax filing requirements.
Harpaz Presents “The New Tax Sovereignty” at The Junior International Law Scholars Association Summer Workshop
Legal scholar Harpaz presented a paper titled 'The New Tax Sovereignty' at the Junior International Law Scholars Association Summer Workshop. The presentation explores evolving concepts of tax sovereignty in an international context, likely addressing how globalization, digital economies, and multilateral frameworks such as OECD Pillar Two are reshaping nations' autonomous taxing powers. The work contributes to academic discourse on how states assert and negotiate taxing rights amid cross-border economic activity, treaty obligations, and supranational tax coordination efforts that challenge traditional notions of fiscal sovereignty.
Navigating the Tax Transparency Landscape
This Tax Foundation event focuses on navigating the evolving tax transparency landscape, likely covering developments such as public country-by-country reporting, beneficial ownership disclosure, global minimum tax reporting requirements, and other international transparency initiatives. Tax transparency has become a central theme in global tax policy, driven by OECD frameworks and regional mandates that require multinational enterprises to disclose more detailed financial and tax information across jurisdictions. The event provides a forum for professionals to understand compliance obligations and policy implications surrounding increased reporting demands on businesses operating internationally.
N.Y. Times: Microsoft Disclosure Provides Rare Glimpse of Tax Haven Tactics
The New York Times reports on a rare Microsoft disclosure revealing the company's use of tax haven strategies to minimize its global tax burden. The disclosure offers an unusual window into how multinational corporations structure operations across low-tax jurisdictions to reduce corporate income tax liabilities. Microsoft's arrangements reportedly involve routing profits through subsidiaries in favorable tax jurisdictions, raising questions about transfer pricing practices and the effectiveness of international tax reform efforts including Pillar Two. The case highlights ongoing tensions between aggressive tax planning by large multinationals and government efforts to ensure fair taxation.
Pyxus International’s Adoption of Orbitax Global Minimum Tax supported by Global Tax Management
Pyxus International has adopted Orbitax's Global Minimum Tax solution, supported by Global Tax Management, to manage Pillar Two compliance obligations. The case study highlights how the multinational tobacco and agricultural company implemented the software to handle the complexities of the OECD's 15% global minimum tax rules. The Orbitax platform assists with GloBE income calculations, top-up tax determinations, and jurisdictional reporting requirements. The partnership with Global Tax Management provided implementation expertise, enabling Pyxus to streamline its Pillar Two compliance processes and ensure accurate reporting across its international operations.
OECD Helping Developing Nations On Min. Tax, Transparency
The OECD is providing technical assistance and capacity-building support to developing nations to help them implement the global minimum tax (Pillar Two) and improve tax transparency standards. The initiative aims to ensure lower-income countries can effectively adopt the 15% global minimum corporate tax rules and participate in international tax transparency frameworks. This support addresses concerns that developing nations lack the administrative infrastructure to enforce these complex measures, potentially missing out on revenue gains while multinational enterprises shift profits.
A new era of international tax cooperation
The article discusses emerging frameworks for international tax cooperation, likely addressing efforts by global bodies such as the UN or OECD to coordinate tax rules across jurisdictions. It explores how multilateral agreements and information-sharing mechanisms are reshaping the international tax landscape, potentially covering topics such as the global minimum tax under Pillar Two, base erosion measures, and the push by developing nations for greater representation in setting global tax standards. The piece reflects on whether new cooperative frameworks represent a genuine shift in power dynamics between developed and developing countries in international taxation.
Session 2b: Competitiveness and tax
A Bruegel session examining the relationship between tax policy and European competitiveness. The discussion likely addresses how tax structures across EU member states affect business investment, economic growth, and the broader competitive positioning of Europe in the global economy. Topics may include corporate tax harmonization, the impact of Pillar Two global minimum tax rules on EU competitiveness, and whether current tax frameworks support or hinder innovation and capital allocation. The session reflects ongoing debate about balancing fiscal revenues with the need to attract and retain businesses in an increasingly competitive global environment.
Is the European Commission’s Tax Omnibus Proposal a Step in the Right Direction?
The European Commission's Tax Omnibus proposal is examined for its potential to streamline and simplify EU tax rules. The analysis considers whether the proposal moves in the right direction by reducing compliance burdens, harmonizing tax frameworks across member states, and addressing outstanding issues in areas such as the global minimum tax (Pillar Two) and other corporate tax directives. The Tax Foundation evaluates the proposal's merits and shortcomings, assessing whether it genuinely advances efficient, growth-friendly tax policy within the EU or risks introducing new complexities despite its simplification intent.
How NXP Semiconductors helped bridge the gap between Pillar Two readiness and Real-World Filing
NXP Semiconductors, a global semiconductor company, worked with Orbitax to bridge the gap between Pillar Two readiness and actual GloBE Information Return (GIR) filing. The case study details how NXP leveraged Orbitax's technology platform to manage the complex data requirements and compliance obligations under the OECD's Pillar Two global minimum tax framework. The solution helped NXP transition from preparedness assessments to real-world filing execution, addressing challenges around data aggregation, jurisdictional calculations, and reporting accuracy required for GIR submissions across multiple jurisdictions.
Testimony: Are Digital Services Taxes a Viable Solution for the EU Budget?
This testimony examines whether digital services taxes (DSTs) represent a viable funding mechanism for the EU budget. It explores the structural and economic challenges of DSTs as an own resource for EU financing, analyzing their design flaws, potential trade tensions—particularly with the United States—and distortionary effects on the digital economy. The piece evaluates whether DSTs can provide a stable, fair revenue base for the EU, weighing them against alternative fiscal instruments. It considers geopolitical dimensions, including OECD/G20 negotiations on Pillar One, and questions whether pursuing DSTs risks undermining broader international tax coordination efforts.
Choose the right software for Pillar 2 Top-up Taxes
HMRC guidance helps multinational groups select appropriate software for reporting Pillar 2 top-up taxes in the UK. The page outlines compatible software options that meet HMRC's requirements for filing the Pillar 2 top-up tax return, which applies to large multinationals with consolidated revenues exceeding €750 million. It assists compliance officers and tax teams in identifying tools that integrate with HMRC's digital reporting service, ensuring accurate calculation and submission of the income inclusion rule and undertaxed profits rule liabilities under the UK's implementation of the OECD global minimum tax framework.
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