Pillar Two / Global Minimum Tax news
The OECD's Pillar Two global minimum tax, covering the GloBE rules, domestic top up taxes, qualified status for safe harbours and the administrative guidance that keeps arriving, collected from the tax authorities, advisers and publishers AskColm monitors.
58 articles in the archive, showing the latest 50.
The hitch in taxing AI: labour is local, capital isn’t
The article examines the structural challenge of taxing AI-driven economic activity, highlighting the fundamental mismatch between where labour income is generated and taxed locally versus where AI capital and profits accumulate, often in low-tax jurisdictions. As AI displaces traditional labour,…
Swiss Corporate Tax Insights
Tax Partner AG has contributed the Switzerland chapter to the Corporate Tax & Tax Controversy Comparative Guide 2026, published by The Global Legal Post as part of its Law Over Borders series.
Luxembourg Simplifies Pillar Two
Luxembourg has proposed amendments to its Pillar Two legislation to implement the OECD's new side-by-side solution, along with a range of new safe harbours and simplification measures.
Dryda et al.: Global Ripple Effects of Corporate Tax Reforms
A working paper published by the National Bureau of Economic Research examines how corporate tax reforms in one country affect others within a fragmented global tax regime. The study, by economists from the University of Toronto and Michigan State University,…
US Group Can Fight Belgian Min. Tax Backstop, Court Says
A US business advocacy group can proceed with its legal challenge to Belgium's backstop measure to the global minimum tax, the Belgian Constitutional Court has ruled. The court found the case can continue despite the European Commission endorsing an exemption…
Weighing the risk: US tax reforms driving MNEs to reassess IP models
Deloitte professionals examine how changes to US tax law are prompting multinational enterprises to reconsider intellectual property and operating models centred on the US, and how European tax authorities are responding to those shifts.
Preparing for the Second Pillar Two Filing Season
The FY2025 GloBE Information Return is due 31 March 2027 for groups already within scope of Pillar Two. The article covers key changes for the upcoming filing season, including deadlines, the undertaxed profits rule and local filing requirements.
EU holds back on Digital Services Tax as US raises retaliation threat
The European Union has paused plans to introduce a Digital Services Tax following threats from the United States to impose retaliatory tariffs on European goods. The US has signalled strong opposition to DST measures it views as discriminatory against American…
OECD: MNE Responses to the Global Minimum Tax
The OECD has published research examining how multinational enterprises are responding to the global minimum tax (Pillar Two) framework. The study analyzes behavioral changes among MNEs following the introduction of the 15% global minimum tax, including shifts in profit allocation,…
Power and Tax Policy: When Does Leveraging Market Access as a Coercive Geoeconomic Tool Succeed?
This analysis examines Section 899 of the U.S. tax code as a retaliatory geoeconomic tool, exploring how leveraging market access through tax policy can function as coercive statecraft. The piece assesses historical and contemporary cases where countries have used discriminatory…
UN Framework Convention – Roundup of the Fifth Session of Negotiations
The fifth session of negotiations under the UN Framework Convention on international tax cooperation has concluded. This session represents a significant multilateral tax policy development, as countries continue to debate the structure and scope of a legally binding international tax…
Portugal Extends Pillar Two Filing Deadline
Portugal has extended the filing deadline for Pillar Two compliance obligations, giving multinational enterprises additional time to submit the required GloBE information returns. This regulatory update reflects the administrative complexity involved in implementing the OECD's global minimum tax framework, which…
OECD Says Corporate Tax Rates Stayed Flat At 21.2% In 2025
The OECD has reported that global statutory corporate income tax rates remained flat at an average of 21.2% in 2025, signaling a period of stabilization after years of rate reductions. The finding suggests that the race-to-the-bottom trend in corporate taxation…
Over 150 civil society organizations make joint submission on the zero draft UN Tax Convention
More than 150 civil society organizations have submitted a joint response to the zero draft of the UN Tax Convention, signaling broad engagement from non-governmental actors in shaping the proposed international tax framework. The submission reflects advocacy priorities around tax…
Netherlands: DAC8 and DAC9 penalty rules updated
The Netherlands has updated its penalty rules in relation to DAC8 and DAC9, the EU directives covering automatic exchange of information on crypto-asset transactions and global minimum tax reporting respectively. DAC8 introduces reporting obligations for crypto-asset service providers, while DAC9…
Inside the First Pillar Two Filing Season: Trends, Challenges, and Lessons
This article examines the inaugural Pillar Two filing season, exploring the practical challenges and emerging trends faced by multinationals as they navigate the global minimum tax framework for the first time. Key topics likely include data gathering complexities, jurisdictional safe…
Australian CGDMTR Filing: Building a Repeatable Pillar Two Process with Direct ATO Transmission
Australia's Country-by-Country and Global Minimum Tax Data Report (CGDMTR) filing requirement introduces a direct transmission process to the Australian Taxation Office (ATO) for Pillar Two compliance. The article addresses how multinational enterprises can build a repeatable, efficient process for meeting…
Azam: The United States, China, and the OECD-UN Rivalry in Global Tax Governance
This article examines the geopolitical rivalry between the OECD and the UN in shaping global tax governance, with particular focus on the roles of the United States and China. As the UN advances its own framework convention on international tax…
Global Tax Treaty Negotiations Take Major Step Forward During Discussions on Draft Text
Global tax treaty negotiations have advanced significantly with discussions on draft text, marking a key development in international tax cooperation. The negotiations, likely conducted under UN or OECD frameworks, aim to establish binding multilateral rules governing cross-border taxation. Progress on…
Africa Wants Precedence For UN Tax Pact's Dispute Protocol
African nations are pushing for the UN Framework Convention on International Tax Cooperation's dispute resolution protocol to take precedence over existing OECD-based mechanisms, including Pillar Two's dispute frameworks. African bloc representatives argue that the UN process better represents developing countries'…
Nations Want AI Covered In UN Tax Pact's Services Protocol
Countries participating in UN tax negotiations are pushing for artificial intelligence services to be explicitly covered under a proposed UN tax convention's services protocol. The move reflects growing international concern that existing tax frameworks may not adequately capture revenue from…
N.Y. Times: Crocs Has a Trick for Dodging Taxes: a Tiny Office in Malta
Crocs, the footwear company, reportedly uses a small office in Malta to reduce its tax burden, according to a New York Times investigation. The arrangement highlights how multinational corporations exploit low-tax jurisdictions and treaty networks to shift profits and minimize…
Unpacking HMRC’s approach to the pillar two side-by-side package
This article examines HMRC's approach to the Pillar Two side-by-side package, analyzing how the UK tax authority is implementing the OECD's global minimum tax framework. It unpacks the technical mechanics of how HMRC is administering the Qualified Domestic Minimum Top-up…
TP in the Southern Cone: substance, business transformation, and global tax challenges
This article analyzes transfer pricing developments in the Southern Cone, focusing on Argentina, Chile, Uruguay, and Paraguay. It addresses the growing emphasis on economic substance, the tax implications of business transformations such as supply chain restructurings, and the impact of…
Multinationals brace for more tax disputes: Baker McKenzie survey
A Baker McKenzie survey reveals that multinational corporations are anticipating a significant rise in tax disputes globally. The research highlights growing concerns around transfer pricing challenges, increased audit activity by tax authorities, and the complexity introduced by Pillar Two implementation.…
Multinational Top-up Tax and Domestic Top-up Tax
HMRC's internal manual on Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) provides authoritative technical guidance on the UK's implementation of the OECD Pillar Two global minimum tax rules. The manual covers the legislative framework under the Finance (No.…
How ESR and pillar two are converging across the GCC
This article examines the convergence of Economic Substance Regulations (ESR) and Pillar Two rules across Gulf Cooperation Council (GCC) countries. As GCC states implement their own corporate tax frameworks and align with OECD's global minimum tax standards, businesses face overlapping…
Digital Services Tax — latest developments and policy direction
This article reviews the latest global developments and evolving policy direction surrounding Digital Services Taxes (DSTs). It covers updates across multiple jurisdictions, including the interplay between unilateral DST measures and the stalled progress on Pillar One of the OECD's two-pillar…
Global Minimum Tax Put to the Test
The global minimum tax under OECD Pillar Two is facing its first major practical tests as jurisdictions implement Qualified Domestic Minimum Top-up Taxes (QDMTTs) and multinational enterprises begin filing under the new rules. Challenges include data gathering across jurisdictions, interpreting…
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…
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…
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…
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…
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,…
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…
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…
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…
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…
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…
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…
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…
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 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…
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…
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…
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…
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…
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…
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…
Guidance: Report Pillar 2 top-up taxes: service availability and issues
HMRC publishes service availability and known issues updates for the Pillar 2 top-up taxes reporting service in the UK. This guidance page provides real-time status information for multinational groups required to file Pillar 2 top-up tax returns, covering planned maintenance…