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Introduction The 2025 Update to the OECD Model Tax Convention (MTC) reflects a series of targeted doctrinal clarifications rather than a wholesale structural revision. Taken together, the changes respond to longstanding interpretive uncertainties across three thematic pillars: the scope of permanent establishment in modern working arrangements and extractive industries; the interface between Article 9 transfer pricing principles and domestic interest limitation rules; and the

Introduction Double tax treaties (DTTs) also referred to as double taxation avoidance agreements or conventions constitute the backbone of the international tax architecture. Concluded bilaterally between sovereign states, their primary function is to eliminate or mitigate the risk that the same income is subjected to taxation in two or more jurisdictions simultaneously. By allocating taxing rights between a source state and a residence state, treaties provide legal certainty

The last quarter of 2025 and the beginning of 2026 saw several significant developments in bilateral double taxation treaties (DTTs). These developments include amendments through protocols, the entry into force of new treaties, and the modernization of existing agreements to reflect post-BEPS standards and evolving cross-border employment patterns. The following sections outline the most relevant treaties and emphasize the principal changes introduced. Netherlands – Germany:

Introduction The integration of Large Language Models (LLMs) into tax compliance and advisory workflows has accelerated rapidly, raising fundamental questions regarding accuracy, regulatory alignment, and professional reponsibility. At the same time, a significant federal ruling in United States v. Heppner (S.D.N.Y., Feb. 10, 2026) now places privilege and confidentiality risks to AI-assisted legal advice as documents generated through a consumer version of anthropic Claude

Introduction In an increasingly integrated global economy, tax policy has become a central determinant of capital allocation, investment decisions, and long-term economic growth. Jurisdictions compete not only through statutory rates, but through the overall structure of their tax systems. The International Tax Competitiveness Index 2025, published by the Tax Foundation’s Center for Global Tax Policy provides a comparative assessment of OECD tax systems based on two core prin

Introduction The world is getting quite scary as shown by the incidents taking place in Guadalajara Jalisco the 22 of February of 2026, it only shows how unpredictable times currently are. As geopolitical tensions arise worldwide and due to the sustained pressure for NATO members to meet or exceed the 2 percent defense spending benchmark have prompted countries worldwide to reassess how military expansion should be financed. Increasingly, tax policy is being positioned as a s

In a 6–3 decision, the Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs on nearly every trading partner. The question presented was direct: whether IEEPA permits the Executive to exercise the tariff power. The controversy arose after President Trump invoked IEEPA to respond to two perceived foreign threats: the influx of illegal drugs from Canada, Mexico, and China, and “large and persistent” tr

Corporate Concentration and Interstate Job Exporters The United States remains the largest and most dynamic corporate market in the world. California, New York, and Texas concentrate a substantial number of Fortune 500 headquarters and major multinational groups. California dominates technology and entertainment. New York continues to lead global finance. Texas and other states have positioned itself as a powerhouse in energy, logistics, and manufacturing. However, the compet

Introduction: The Netherlands is preparing one of the most consequential reforms of wealth taxation in Europe. Through the proposed “Wet werkelijk rendement” (Bill 36 748), the traditional deemed-return system in Box 3 will be replaced by taxation based on actual returns. The reform is scheduled to enter into force on 1 January 2028. Under the new system, taxation no longer relies on assumed yields. Instead, individuals will be taxed on the real economic income generated by t

Introduction The ongoing negotiations between the Governments of India and the United States regarding India’s Digital Services Tax (DST) regime principally embodied in the Equalisation Levy and associated digital nexus measure have become a defining point of contention within the broader bilateral trade framework. In addition to headline commitments such as India’s intended expansion of imports from the United States, the treatment of digital taxation in this agreement refl

Introduction Mexico has enacted a special fiscal regime for the 2026 FIFA World Cup through the Vigésimo Quinto Transitorio of the 2026 Federal Revenue Law and Chapter 9.4 of the Miscellaneous Tax Resolution for 2026. In general terms, the tax benefits imply the release from compliance with certain tax obligations, including formal obligations, as well as transfer, withholding, collection and full payment of federal taxes established in Mexican tax legislation. In practical t

Introduction On July 4, 2025, the United States Congress enacted the One Big Beautiful Bill Act , introducing a federal excise tax on outbound remittance transfers. Codified as Section 4476, Subchapter D Tax on Remittance Transfers, of the Internal Revenue Code, the measure entered into force for transfers made after December 31, 2025, and is fully applicable as of January 1, 2026. For the first time at the federal level, certain cross-border family transfers are expressly t

Introduction On 16 January 2026, the Dutch Supreme Court delivered a landmark judgment in the case of [X] B.V. concerning the legality of the statutory tax interest rate applied to Dutch corporate income tax. The decision arose from an appeal in cassation lodged by the State Secretary for Finance against a judgment of the Northern Netherlands District Court of 7 November 2024. At issue was whether the minimum tax interest rate of 8 percent for corporate taxpayers, as laid dow

Case C-603/24, Stellantis Portugal , pending before the Court of Justice of the European Union, sits at the intersection of two regimes that frequently coexist in multinational groups but rarely align seamlessly: transfer pricing and value added tax. The dispute concerns whether post-year transfer pricing adjustments, made to ensure arm’s length outcomes for corporate income tax purposes, must also retroactively alter the VAT taxable amount of intra-group transactions. The ca

In recent months, the United States has come under sustained international scrutiny for its positions on global taxation and energy-related fiscal measures. Between its continued non-implementation of the OECD/G20 Pillar Two global minimum tax, its rejection of a United Nations–backed global carbon tax, and adverse rulings at the World Trade Organization regarding U.S. clean energy tax credits, U.S. policy choices are increasingly perceived as misaligned with multilateral le

Introduction On 16 January 2026, the United States Court of Appeals for the Fifth Circuit issued a landmark decision in Sirius Solutions, L.L.L.P. v. Commissioner of Internal Revenue , fundamentally rejecting the Internal Revenue Service’s recent approach to self-employment taxation of limited partners. The dispute concerned the interpretation of section 1402(a)(13) of the Internal Revenue Code and whether limited partners who participate in management or operations may never

Corporate taxation continues to be a decisive factor for multinational investors assessing jurisdictional attractiveness. While statutory rates remain important, international reforms most notably the OECD/G20 Pillar Two global minimum tax framework have altered how low-tax European jurisdictions structure their regimes. In this evolving landscape, investors increasingly prioritise effective tax burden, regulatory stability, compliance with international norms, and access to

On 27 January 2026, the European Union and India concluded negotiations on a landmark Free Trade Agreement (FTA), publicly characterized as the “mother of all deals.” The agreement represents the largest free trade arrangement ever concluded by either party and marks a decisive shift toward a rules-based, strategic economic partnership. Its relevance for businesses is immediate and concrete, particularly in the areas of customs liberalisation, rules of origin, and global valu

Introduction The judgment of the Court of Justice of the European Union in Case C-39/23, concerning the compatibility with Article 63 TFEU of national tax rules that subject dividends paid to foreign public pension institutions to withholding tax while exempting dividends received by domestic public pension funds. The analysis focuses on three interrelated legal questions: whether such differential treatment constitutes a restriction on the free movement of capital, how the o

Introduction In recent years, the California Legislature has examined proposals to introduce a state-level wealth tax aimed at the state’s highest-net-worth individuals. Although no comprehensive wealth tax has yet been enacted, the repeated introduction of such bills by the California Legislature has generated substantial legal, fiscal, and behavioral debate. The issue is significant because California already maintains one of the highest marginal income tax rates in the Uni