This week's Tax Take travels to Europe and beyond to take stock of several tax policy developments at the Organisation for Economic Cooperation and Development (OECD) and elsewhere that affect multinational companies.

Taxation of Digital Economy

Following the successful conclusion at the start of 2026 on the Side-by-Side Package with respect to the Global Minimum Tax project, the OECD/Group of 20 (G20) Inclusive Framework (IF) has turned its sights back to the taxation of the digital economy. Rather than attempt to resuscitate the Multilateral Convention to implement Amount A of Pillar One, members of the IF have committed to engage in a constructive dialogue on the issue, with due regard to the lessons learned from previous efforts.

This ongoing dialogue was noted in the Group of Seven (G7) Finance Ministers' communique from mid-May, which anticipates a report by the OECD on the progress of the IF's work by the end of 2026 that identifies, among other things, "a shared understanding of any challenges posed to the existing international tax system by the digital economy." This will be a fresh exercise given the significant changes to the international tax system and business models in the last 15 years. While the prospect of success is unclear, the commitment to dialogue is welcome given the alternatives. 

Global Minimum Tax

The Side-by-Side Package did not relieve compliance obligations on U.S. multinationals with respect to 2024 or 2025. Further, aspects of the Global Minimum Tax, notably Qualified Domestic Minimum Top-Up Taxes (QDMTT), will continue to be relevant to U.S. multinationals. The OECD continues to publish guidance relevant to complying with these rules. Guidance in May 2026 addressed practical issues including central filing and exchange of 2024 information returns. These returns are due for many taxpayers on June 30. While all stakeholders hope that the return filing process will proceed without technical difficulties, problems may be inevitable given that an entire multinational corporate tax system is being stood up for the first time. 

OECD Consultation on Transfer Pricing and Services

The OECD opened a consultation on a revised chapter to the OECD Transfer Pricing Guidelines on intercompany services. Comments on the revised draft are due July 22, and a public consultation will be held in November. 

The revised chapter represents a significant rewrite of the guidelines. In general, the revised chapter continues the trend of more detailed and nuanced guidance, which may not necessarily be better guidance given the compliance and administrative burdens that may result. The proposed changes include:  

• Closer alignment between the rules for services and the changes to the guidelines coming out of the Base Erosion and Profit Shifting (BEPS) project
• More guidance on the "benefit test" for determining whether activities constitute a service
• Guidance on the division between intangible enabled services and transfers of intangibles
• Guidance on the use of methods other than cost-plus methods for high value adding services
• Services-specific documentation requirements
• Numerous detailed examples

We may learn more as the OECD and the U.S. Council for International Business (USCIB) open their two-day International Conference in Washington, DC. #TaxTake

Upcoming Speaking Engagements and Events 

Mike and new Miller & Chevalier Counsel Eric Albers-Fiedler will speak at the NYU 18th Annual Tax Controversy Forum on June 25-26.

In the News

Marc, Mike, Rocco, and Layla were named in the 2026 Lawdragon 500 Leading Global Tax Lawyers guide. 

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