The Lead Story
Side-By-Side, Face-To-Face: 150 Nations Seal Minimum-Tax Pact
The world just hit “send” on a deal decades in the making. Roughly 150 countries have approved a side-by-side agreement that marries the U.S. push for a 15% global minimum tax with Europe’s demand for fair profit allocation, Law360 reports.
Why now? Officials from the OECD, Germany and the U.S. say the accord delivers balance,“certainty for business, revenue for governments,” as one negotiator put it. The pact sets 2026 as the first full year of enforcement, locking in real-time data exchanges and penalty teeth for laggards (Learn more about similar data-sharing initiatives).
For multinationals, this isn’t just another framework. It rewrites where profits land, how much tax sticks, and what compliance feels like. One lawyer summed it up: “Your transfer pricing playbook just expired.”
Why It Matters:
• Companies that enjoyed single-digit rates in low-tax hubs will face a hard floor.
• Disputes should ease, countries agreed on a binding process to kill double taxation fights.
• The clock is ticking: group-wide effective-tax-rate models must be audit-ready by 1 January 2026.
Around the Tax World
• Poland flips the switch. Mandatory e-invoicing via the KSeF portal starts 1 February for firms topping PLN 200 m turnover and 1 April for everyone else, turning every invoice into live data for the taxman, International Tax Review notes. Fail to tag, and payments may stall.
• Trump pulls the plug. A White House memo yanks the U.S. from 66 international bodies, slashing funds for 31 UN agencies in the name of “sovereignty,” according to The Whistler. Expect treaty talks, and trust, to tense up.
• Crypto gets caught. The OECD’s Crypto-Asset Reporting Framework (CARF) forces Cayman-based exchanges to collect user IDs and ship trade data abroad, JD Supra explains. Anonymity? Over.
• Private capital feels the heat. UK sponsors will watch a time-limited SDRT exemption for fresh London listings while EU plans new anti-avoidance rules, say authors at Ropes & Gray. Deal models must flex, fast.
• Africa eyes enforcement. Tax authorities across the continent will double-down on data sharing and pillar-two audits, warns advisory firm Regan van Rooy.
By the Numbers
Prime Number: 66,the count of global bodies the U.S. just quit. Every exit leaves a funding hole.
Looking Ahead
All eyes are on the guidance. All eyes are on the rate. OECD rules publish in March; local laws must follow (Learn more about similar initiatives in Nigeria).