Global Tax Policy Insights

I am pleased to announce the release of the report on Amount B of Pillar One.   Agreed upon by the members of the OECD/G20 Inclusive Framework on BEPS, this new report provides a simplified and streamlined approach to apply the arm’s length principle to baseline marketing and distribution activities at country-jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.   The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines. 📚 Access the report and the Reader's Guide ➡️ https://oe.cd/5qm 🗞️ Read the web announcement ➡️ https://oe.cd/5qk #OECDtax #OECD #tax #OECDP1 #Pillar1 #internationaltax #taxreform #AmountB #TrustinTax #TaxCertainty #TransferPricing #BEPS

India - France Tax Treaty Amended. And this one is not cosmetic! The amendment quietly changes how cross-border structures, dividend flows, and business models between India and France will be taxed. 1. Capital gains on shares Full taxing rights now move to the country where the company is resident. This will directly influence exit structuring and holding company decisions in cross-border M&A. 2. MFN clause removed A major source of treaty litigation disappears. 3. Service PE concept introduced Foreign companies rendering services in India now face clearer PE exposure risk. Tracking employee presence and project duration will be critical. Why this matters These amendment are really about certainty + alignment. Less interpretational play, more structured tax positions. For international tax teams, investors, and founders operating between India and France - this will impact structuring, compliance strategy, and litigation outlook. Next watchpoint: Implementation timeline post ratification. #dtaa #taxtreaty #india #france #internationaltax #tax

In June 2025, Nigeria signed a new Tax Reform law. It starts fully on January 1, 2026. It affects everyone: employees, business owners, freelancers, investors, and even content creators. The Four New Tax Laws 1. Nigeria Tax Act (NTA): combines Personal Income Tax, Company Tax, VAT, Capital Gains Tax, Petroleum Tax, etc. into one. 2. Nigeria Tax Administration Act (NTAA): explains how taxes will be collected, penalties, audits. 3. Nigeria Revenue Service Act (NRSA): creates the new Nigeria Revenue Service (NRS) (replaces FIRS). 4. Joint Revenue Board Act (JRBA): makes federal and state tax offices work together, adds a Tax Tribunal and a Tax Ombudsman (for complaints). Tax Identification Number (TIN) From 2026, everyone earning money must have a TIN. Without it, you may not be able to: Open some bank accounts Do property or car registration Get government contracts or loans Example: If you’re a freelancer on Fiverr, you’ll need a TIN to stay compliant. Declaring Your Income Everyone must declare their annual income to the tax office. This includes salary, side hustles, business profits, rent, shares, crypto, YouTube, TikTok, Fiverr, or Upwork income. Example: A content creator earning ₦2m from Instagram ads must file tax returns. Comparing Old vs New Personal Income Tax (PIT) System Tax is now based on how much you earn. Under the old system (PITA), everyone got a Consolidated Relief Allowance (CRA) of ₦200,000 + 20% of income before tax was applied. Under the new 2025 reform, CRA is removed and replaced with Rent Relief (₦500,000 or 20% of annual rent, whichever is lower). Old PIT Rates Income Band Rate First ₦300,000 7% Next ₦300,000 11% Next ₦500,000 15% Next ₦500,000 19% Next ₦1,600,000 21% Above ₦3,200,000 24% New PIT Rates (2025 Reform) Income Band Rate Up to ₦800,000 0% ₦800k – ₦3m 15% ₦3m – ₦12m 18% ₦12m – ₦25m 21% ₦25m – ₦50m 23% Above ₦50m 25% Example: ₦5,000,000 Annual Income Old System: CRA = ₦200k + (20% × ₦5m) = ₦1.2m Taxable income = ₦3.8m Total tax = ₦704,000 Effective rate: 14.08% New System: First ₦800k → 0% Next ₦2.2m → 15% = ₦330k Remaining ₦2m → 18% = ₦360k Total tax = ₦690,000 Effective rate: 13.8% CRA Removed, Rent Relief Added Before: Consolidated Relief Allowance (₦200k + 20% of income) reduced your taxable income. Now: CRA is gone. Instead, Rent Relief: You can deduct ₦500k or 20% of annual rent (whichever is lower). Example: If your rent is ₦1m → 20% = ₦200k deductible. If rent is ₦4m → 20% = ₦800k, but capped at ₦500k. Capital Gains Tax (CGT) Individuals: profits from selling land, crypto, or shares are added to your income and taxed with PIT rates. Companies: pay 30% on chargeable gains. Exemption: If you sell shares below ₦150m in a year and gains are less than ₦10m, you don’t pay CGT. Example: You sell shares worth ₦100m, profit = ₦8m → no CGT.

Build it, Deduct it!   On July 4th, the U.S. passed OBBBA, a sweeping tax reform package that delivers a windfall for companies who invest in innovation and infrastructure. It’s simple: more R&D + more CapEx = more free cash flow. Here’s why:   OBBBA reinstates 100% immediate expensing for U.S.-based R&D. No more amortizing over 5 years. If you’re building the next breakthrough in AI or life sciences, your tax deduction is instant. That means lower taxes this year, not in 2029. On the CapEx side, OBBBA brings back full bonus depreciation for qualified property, including everything from machinery, data center infrastructure, chip fabs, and corporate jets.   Buy it. Build it. Deduct it.   This bill serves to accelerate free cash flow, which will be a powerful tailwind for growth-oriented companies that reinvest heavily in their businesses. Companies that rely on R&D for product development (technology, biotech), building critical infrastructure (semis, energy, manufacturing, commercial property), or deploy heavy equipment (railroads, ship builders, farm equipment) benefit from this full write-off in year 1. For many companies this will result in a spike in free cash flow which should help drive valuations.   OBBBA also includes retroactive "catch-up" deductions for previously capitalized R&D from 2022–2024, which is a gift as refund checks for companies that have been carrying deferred tax assets is off-set this tax year. This policy rewards domestic innovation and encourages onshoring for strategic industries.   Asset Based Lending will also benefit since hard assets valuations will experience a step-function higher and U.S. taxpayers will see this flow through on their K-1s. At Marathon Asset Management, we are witnessing firsthand the demand to finance many of these hard mission-critical assets. 

🎺 𝐓𝐫𝐮𝐦𝐩 𝐚𝐧𝐝 𝐓𝐚𝐱𝐞𝐬: 𝐖𝐡𝐚𝐭 𝐭𝐨 𝐄𝐱𝐩𝐞𝐜𝐭 𝐟𝐨𝐫 𝐁𝐮𝐬𝐢𝐧𝐞𝐬𝐬𝐞𝐬? 🌟 With a strong voter mandate, President-elect Donald Trump is poised to advance his ambitious tax policy agenda. I am sharing a breakdown of the key plans and their potential impacts, based on insights from economics, finance, and accounting research: 𝑲𝒆𝒚 𝑻𝒂𝒙 𝑷𝒐𝒍𝒊𝒄𝒚 𝑷𝒍𝒂𝒏𝒔 𝒇𝒐𝒓 𝑩𝒖𝒔𝒊𝒏𝒆𝒔𝒔𝒆𝒔 📊 • Extension of 2017 Tax Cuts and Jobs Act (TCJA): Businesses will likely continue benefiting from low corporate tax rates and favorable depreciation rules for investment (capital expenditures) and R&D. • Further Tax Cuts: Potential reduction of corporate tax rates from 21% to as low as 15%. • Tariffs and Import Incentives: New tariffs on imports could be paired with incentives for US-domestic production. • Reduced IRS Budget for Enforcement: Cuts to IRS funding may reduce tax enforcement, potentially creating more leeway for corporate tax planning. 𝑾𝒉𝒂𝒕 𝑫𝒐𝒆𝒔 𝑹𝒆𝒔𝒆𝒂𝒓𝒄𝒉 𝑺𝒂𝒚 𝑨𝒃𝒐𝒖𝒕 𝒕𝒉𝒆 𝑷𝒐𝒕𝒆𝒏𝒕𝒊𝒂𝒍 𝑰𝒎𝒑𝒂𝒄𝒕? 🔬 In a working paper with Rebecca Lester from Stanford University Graduate School of Business, we review the evidence on how firms respond to tax incentives. Key takeaways include: • Investment Growth: Increased tax deductions for R&D and investment effectively boost growth and employment, but some benefits may be windfall gains for firms rather than new investments. • Attractiveness of Lower Tax Rates: A low corporate tax rate (21% vs. ~30% in Germany/France) attracts international investment and stimulates domestic business activity. • Cost-Effectiveness: Tax rate cuts are costly for public finances due to permanent revenue losses. Incentives like depreciation rate increases are budget-neutral in the long run and can also drive growth. • Policy Uncertainty: Firms hesitate to invest without credible, sustainable tax policies. Certainty is critical to maximizing the benefits of these incentives. • Tax Enforcement Trade-offs: Lower enforcement could encourage avoidance but also reduce capital availability for smaller firms, as tax enforcement improves information quality for lenders. • Green taxes: Firms do respond to carbon taxes and related policy tools. The question is how and by how much, a crucial question for effective climate policy design Our full paper 📄 is available here: https://lnkd.in/e8vjYyR5 We were kindly invited to present these and other research insights at the 2024 Journal of Accounting and Economics Conference. Huge thanks to our discussant Jennifer Blouin and all attendees for their invaluable feedback! Have thoughts or questions? Drop them 👇 in the comments. I’ll also share links to studies supporting these findings below. 🚀 #Taxes #Economics #Trump #Research #Investment Ed deHaan Michelle Hanlon Jeff Hoopes Scott Dyreng Lisa De Simone Anthony Welsch Andrew Belnap Jaron Wilde John Gallemore Harald Amberger Christoph Spengel

𝗧𝗮𝘅 𝗧𝗿𝗲𝗮𝘁𝗶𝗲𝘀 𝗶𝗻 𝗧𝗿𝗮𝗻𝘀𝗶𝘁𝗶𝗼𝗻: 𝗪𝗵𝗲𝗻 𝗦𝘂𝗯𝘀𝘁𝗮𝗻𝗰𝗲 𝗕𝗲𝗰𝗼𝗺𝗲𝘀 𝗡𝗼𝗻-𝗡𝗲𝗴𝗼𝘁𝗶𝗮𝗯𝗹𝗲 Recent developments indicate that scrutiny assessments of Mauritius-based entities for FY 2023–24 (AY 2024–25) have witnessed a shift in approach. In several cases, instead of concluding assessments at the field level, matters appear to be getting referred to the FT&R division, with possible exchange-of-information requests being initiated with the Mauritius authorities to examine commercial substance. While this may seem like something within the law only, it reflects a broader and more deliberate focus on aligning treaty benefits with demonstrable economic presence. This trend can be viewed in the context of evolving judicial and regulatory thinking, including the Supreme Court’s ruling in the Tiger Global case, which has reiterated that treaty entitlement cannot rest solely on documentation such as a Tax Residency Certificate. The emphasis is clearly moving toward a “substance over form” paradigm, where factors like decision-making, control, financial capacity, and operational footprint are becoming increasingly relevant in determining eligibility for treaty relief. From a practical standpoint, this should not be seen as a cause for concern, but rather as a timely reminder. Structures involving Mauritius, and potentially other jurisdictions, may increasingly be subject to deeper scrutiny, including cross-border verification. For taxpayers and advisors alike, the message is clear: substance is no longer optional. Proactive review, robust documentation, and alignment of commercial rationale with legal form will be critical in navigating this evolving landscape. #InternationalTax #TaxTreaty #SubstanceOverForm #TaxCompliance #CrossBorderTax #MauritiusTax #ExchangeOfInformation #TaxScrutiny #GlobalTax #TaxAdvisory #TaxRiskManagement #EvolvingTaxLandscape #BEPS #TaxGovernance #Scrutinyassessments

📢 𝗕𝗲𝗹𝗴𝗶𝘂𝗺 𝗿𝗲𝗳𝗶𝗻𝗲𝘀 𝗶𝘁𝘀 𝗣𝗶𝗹𝗹𝗮𝗿 𝗧𝘄𝗼 𝗿𝘂𝗹𝗲𝘀 — 𝗷𝘂𝘀𝘁 𝘄𝗲𝗲𝗸𝘀 𝗯𝗲𝗳𝗼𝗿𝗲 𝘁𝗵𝗲 𝗳𝗶𝗿𝘀𝘁 𝗗𝗠𝗧𝗧 𝗱𝗲𝗮𝗱𝗹𝗶𝗻𝗲. On 𝟵 𝗢𝗰𝘁𝗼𝗯𝗲𝗿 𝟮𝟬𝟮𝟱, a draft law was submitted to Parliament, introducing 𝘁𝗲𝗰𝗵𝗻𝗶𝗰𝗮𝗹 𝗯𝘂𝘁 𝗲𝘀𝘀𝗲𝗻𝘁𝗶𝗮𝗹 𝗮𝗱𝗷𝘂𝘀𝘁𝗺𝗲𝗻𝘁𝘀 to Belgium’s minimum taxation framework. While it doesn’t change how the 𝗚𝗹𝗼𝗕𝗘 𝗧𝗼𝗽-𝘂𝗽 𝗧𝗮𝘅 is computed, it profoundly reshapes how groups will need to comply. 🔍 𝗪𝗵𝗮𝘁 𝗰𝗵𝗮𝗻𝗴𝗲𝘀? 1️⃣ 𝗘𝗹𝗲𝗰𝘁𝗿𝗼𝗻𝗶𝗰 𝗽𝗹𝗮𝘁𝗳𝗼𝗿𝗺: all filings and communications must now go through the FPS Finance secured portal, streamlining exchanges (and audit trails). 2️⃣ 𝗝𝗼𝗶𝗻𝘁 𝘃𝗲𝗻𝘁𝘂𝗿𝗲𝘀 𝗰𝗹𝗮𝗿𝗶𝗳𝗶𝗲𝗱: the Belgian definition of “group” is aligned with the OECD GloBE Model — joint ventures are not constituent entities per se, but are deemed in scope for the DMTT. 3️⃣ 𝗚𝗲𝗻𝗲𝗿𝗮𝗹 𝗿𝗲𝗽𝗿𝗲𝘀𝗲𝗻𝘁𝗮𝘁𝗶𝘃𝗲: a single Belgian entity will act on behalf of all local entities subject to the DMTT or UTPR — assuming all filing and procedural obligations. 4️⃣ 𝗝𝗼𝗶𝗻𝘁 𝗮𝘀𝘀𝗲𝘀𝘀𝗺𝗲𝗻𝘁 𝘀𝘆𝘀𝘁𝗲𝗺: when multiple Belgian entities are in scope, the Tax Administration will issue one “joint assessment notice” (per Top-up Tax). 5️⃣ 𝗦𝘁𝗮𝘁𝘂𝘁𝗲 𝗼𝗳 𝗹𝗶𝗺𝗶𝘁𝗮𝘁𝗶𝗼𝗻𝘀: now 𝘀𝗶𝘅 𝘆𝗲𝗮𝗿𝘀, replacing the former ten-year horizon. 6️⃣ 𝗟𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗲𝘅𝘁𝗲𝗻𝗱𝗲𝗱: 𝗷𝗼𝗶𝗻𝘁 & 𝘀𝗲𝘃𝗲𝗿𝗮𝗹 𝗹𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗯𝗿𝗼𝗮𝗱𝗲𝗻𝗲𝗱 to cover joint ventures and their subsidiaries. 7️⃣ 𝗣𝗿𝗼𝗰𝗲𝗱𝘂𝗿𝗮𝗹 𝗰𝗼𝗱𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻:  • at least 𝟲 𝗺𝗼𝗻𝘁𝗵𝘀 between filing and assessment,  • assessment year = fiscal year, unless ending on 31 December,  • GIR-light returns now officially treated as tax returns. ⏰ 𝗧𝗶𝗺𝗶𝗻𝗴 𝗺𝗮𝘁𝘁𝗲𝗿𝘀: With Belgium’s first 𝗤𝗗𝗠𝗧𝗧 𝗿𝗲𝘁𝘂𝗿𝗻𝘀 𝗱𝘂𝗲 𝗶𝗻 𝗡𝗼𝘃𝗲𝗺𝗯𝗲𝗿 𝟮𝟬𝟮𝟱, this reform lands 𝗷𝘂𝘀𝘁 𝗶𝗻 𝘁𝗶𝗺𝗲 — reinforcing procedural clarity but also tightening compliance expectations. 💡 𝗜𝗻 𝗲𝘀𝘀𝗲𝗻𝗰𝗲: Belgium isn’t rewriting Pillar Two — 𝘪𝘵’𝘴 𝘱𝘰𝘭𝘪𝘴𝘩𝘪𝘯𝘨 𝘪𝘵𝘴 𝘦𝘯𝘨𝘪𝘯𝘦. These amendments confirm its intention 𝘁𝗼 𝗯𝗲 𝗮𝗺𝗼𝗻𝗴 𝘁𝗵𝗲 𝗳𝗶𝗿𝘀𝘁 𝗳𝘂𝗹𝗹𝘆 𝗼𝗽𝗲𝗿𝗮𝘁𝗶𝗼𝗻𝗮𝗹 𝗷𝘂𝗿𝗶𝘀𝗱𝗶𝗰𝘁𝗶𝗼𝗻𝘀 𝘄𝗶𝘁𝗵𝗶𝗻 𝘁𝗵𝗲 𝗢𝗘𝗖𝗗 𝗳𝗿𝗮𝗺𝗲𝘄𝗼𝗿𝗸, but they also place new coordination and liability pressures on multinational groups with multiple Belgian entities. ✍️ 𝘍𝘰𝘳 𝘵𝘩𝘰𝘴𝘦 𝘯𝘢𝘷𝘪𝘨𝘢𝘵𝘪𝘯𝘨 𝘵𝘩𝘦𝘪𝘳 𝘧𝘪𝘳𝘴𝘵 𝘘𝘋𝘔𝘛𝘛 𝘧𝘪𝘭𝘪𝘯𝘨, 𝘯𝘰𝘸 𝘪𝘴 𝘵𝘩𝘦 𝘵𝘪𝘮𝘦 𝘵𝘰 𝘦𝘯𝘴𝘶𝘳𝘦 𝘳𝘦𝘱𝘳𝘦𝘴𝘦𝘯𝘵𝘢𝘵𝘪𝘰𝘯, 𝘨𝘰𝘷𝘦𝘳𝘯𝘢𝘯𝘤𝘦 𝘢𝘯𝘥 𝘥𝘢𝘵𝘢 𝘳𝘦𝘱𝘰𝘳𝘵𝘪𝘯𝘨 𝘴𝘵𝘳𝘶𝘤𝘵𝘶𝘳𝘦𝘴 𝘢𝘳𝘦 𝘧𝘶𝘭𝘭𝘺 𝘢𝘭𝘪𝘨𝘯𝘦𝘥. Fieldfisher Belgium École Supérieure des Sciences Fiscales (ICHEC-ESSF) #PillarTwo #QDMTT #UTPR #IIR #BelgiumTax #OECD #GloBE #TaxCompliance #ScrapPillar2 #TaxLaw

The new tax bill that just passed into law is the single most significant piece of legislation we have had in 8+ years Here is everything you should know as a high-income professional or business owner: (Bookmark this post as I'll be updating it as this develops) Background: I have run a startup for the last 3 years that helps business owners and high-income professionals be smart about taxes So this is an area I know a thing or two about This is also not a political post, and none of this is an endorsement for any specific policy 1 - America's biggest tax break for startup founders & investors gets even more generous QSBS allows C-Corp shareholders to pay no taxes on exit This bill raises the limit to $15M, has partial benefits kick in after 3 years & allows a company to qualify up to $75M in assets 2 - 100% bonus depreciation is back When you purchase property with a useful timeline of <20 years, you can depreciate the entire amount upfront This is very significant for real estate investors, who can recoup a huge percentage of their purchase price as a usable tax loss 3 - Relief for software companies in America There was a wild piece of legislation that forced you to amortize software developer salaries over 5 years This resulted in software companies that could lose money and still face a tax bill since their developer salaries had to be deducted over 5 years This is now fixed for local talent 4 - Qualified business income deduction permanent for LLC and S-Corp owners in America Pass-through business owners were gifted a free deduction of up to 20% called QBI since 2017 This was supposed to end this year.. but with this bill, it's now been made permanent 5 - Estate and gift tax exclusion made permanent at $15M per taxpayer, or $30M per couple These exclusions were supposed to fall by more than half at the end of this year But the new bill increases the exemption to $30M for a couple, which is big estate planning news 6 - State & local tax deduction now capped at $40K Before 2017, you could fully deduct state & local taxes from your federal return if you itemized But in 2017, the deduction was capped at $10K The new bill raises it to $40K... this will lead to more people itemizing taxes! 7 - Opportunity zone program made permanent You can defer capital gains for 5 years on a rolling basis by investing in an opportunity zone Hold the property for 10 years and you receive a free step-up in basis Will be a new stricter threshold on what areas count as an OZ 8 - The lowered 21% corporate tax rate is made permanent This coupled with QSBS expansion makes C-Corps a very attractive choice despite the double taxation At the highest tax brackets, C-Corps get very close to S-Corp tax rates with QSBS being a massive benefit on sale If you want to read the rest, I'll be covering these changes in a detailed breakdown post on my personal finance newsletter Silly Money Join 40k+ others: sillymoney.com/subscribe

The IRS is rewriting the rules of the game for inbound corporate moves and U.S. real property taxation. On August 20, 2025, the Service issued Notice 2025-45, announcing plans to ease restrictions on transfers of U.S. real property interests in the context of inbound F reorganizations, when a foreign corporation “redomiciles” into the United States. Why does this matter? Normally, bringing U.S. real property into such a transaction would trigger gain recognition under Section 897, a provision designed to prevent foreign investors from escaping U.S. tax on real estate gains. Under this proposal, however, certain inbound moves would no longer face that automatic tax hit, so long as the transaction isn’t part of an aggressive tax avoidance play. This change could make it easier for foreign corporations, particularly public companies, to shift their legal home to the U.S., accessing capital markets and investor confidence without a crushing tax bill at the border. It’s only a proposal for now, but if finalized, it could mark a subtle yet significant shift in U.S. tax policy. Are we seeing a new strategy to attract global investment, or a loosening of long-standing protections around U.S. real property taxation? #TaxPolicy #CorporateTax #IRS #InternationalTax #MergersAndAcquisitions #RealEstateTax #Section897 #InboundReorganization #TaxStrategy

Interesting developments out of the IRS that will certainly impact corporate finance teams. The IRS just proposed new regulations that could reshape how companies execute tax-free spin-offs. While they provide some much-needed clarity, they also introduce new compliance burdens that could make these corporate transactions more complex and costly. Key takeaways from my perspective and points that might be important for CFOs, tax leaders, and dealmakers: • Debt-for-equity exchanges get a lifeline. The IRS reversed course on some past restrictions, allowing more flexibility for companies to use Spinco stock to pay down debt. But a new 30-day holding rule for intermediaries could complicate M&A transactions and increase costs. • Stricter rules on boot purges. The IRS is tightening restrictions on how companies can use cash proceeds in spin-offs, limiting options like stock buybacks and dividends as part of the deal structure. • Tougher scrutiny on retained spinco stock. If the parent company holds onto Spinco shares post-spin, it’s now presumed to be tax-motivated unless strict conditions are met—requiring a clear business rationale, a disposal plan, and restrictions on shared leadership or business ties. • More compliance red tape. Companies will need to submit a formal Plan of Reorganization to the IRS detailing every step of the transaction, adding significant new regulatory and tax reporting requirements. The bottom line is that the IRS is pushing for more oversight on corporate finance transactions, but these changes could make tax-free spin-offs harder to execute. While the rules aren’t final yet, they’re already shaping IRS private letter rulings and will almost certainly influence deal structuring strategies. Are these changes a step toward better transparency, or just more regulatory hurdles for businesses? #Finance #Business #CorporateFinance #MergersAndAcquisitions #Tax #TaxPolicy #TaxStrategy #IRS #Policy #CapitalMarkets #FinanceLeadership #RegulatoryCompliance https://lnkd.in/eazc9Rzv