CFE’s Tax Top 5 – 18 August 2025

The second session of negotiations for the United Nations Framework Convention on International Tax Cooperation took place at UN Headquarters in New York from 11–15 August 2025. Building on the first week’s focus on the core Convention, this session turned to the two draft protocols: Protocol I on taxation of cross-border services in an increasingly digitalised economy, and Protocol II on prevention and resolution of tax disputes.

General statements reaffirmed established positions, with the EU bloc supporting multilateralism but favouring optional commitments, while the Africa Group stressed the need for simple, future-proof rules covering a broad range of services and rooted in the principle of taxing where value is created. Civil society, through the Global Alliance for Tax Justice and allied groups, organised a side event, emphasising the urgency of rewriting global tax rules to curb profit shifting, tackle inequalities, and ensure taxation supports sustainable development, gender justice, and climate goals.

Detailed discussions on Protocol I centred on replacing outdated nexus rules with concepts such as significant economic presence, exploring net versus gross taxation, and considering differentiated rules for different types of services. Members debated whether physical presence should remain relevant, how “income” should be defined for the Convention’s scope, and whether low-margin services warranted special treatment. Delegates also raised the possibility of a “fast-track” instrument, similar to the OECD Multilateral Instrument, to accelerate adoption of Protocol provisions, though questions arose over its feasibility and how it would interact with an unfinished Convention. Alongside this, information exchange on services was considered, with delegates assessing whether countries currently collect sufficient data and whether such provisions should sit in the Convention or its protocols.

Later in the week, focus shifted to Protocol II on dispute prevention and resolution. The Secretariat outlined possible mechanisms, including opt-in/opt-out flexibility, while highlighting key pressure points such as transfer pricing, permanent establishments, and digital services. OECD countries pointed to regional dispute tools, including arbitration, as potential models, but many African and Latin American delegates opposed binding arbitration on sovereignty and constitutional grounds, instead favouring flexible mechanisms accessible to all states.

Civil society reiterated calls for structural reform of the international tax system, urging that the UN process deliver a coherent and ambitious framework that advances sustainable development and equity. The session concluded with recognition of ongoing divisions but agreement on the centrality of both protocols to the Convention, with further negotiations set to continue at the next meeting in Nairobi in November 2025.

EU Commission Begins Evaluation of Foreign Subsidies Regulation

The European Commission has launched the first review of the Foreign Subsidies Regulation (FSR), which has been in place since July 2023. The review process will begin with a public consultation and a call for evidence, inviting stakeholders to contribute views on both specific aspects of the FSR’s implementation and broader reflections on its aims and context until 18 November 2025 via the Commission’s “Have your say” portal.

The review will assess several key areas: how foreign subsidies that distort the internal market are being identified and addressed; the application of the balancing test, which weighs potential benefits of subsidies against their distortive effects; the Commission’s power to initiate reviews of subsidies independently; the adequacy of notification thresholds; and the overall complexity and cost of the regime for businesses. The findings will feed into a report to be presented to the European Parliament and the Council in July 2026, which may be accompanied by legislative proposals.

In a press release concerning the review, Commission representatives underlined that the review is intended both to ensure the FSR remains effective in addressing distortions caused by foreign subsidies and to minimise administrative burden. Public procurement, which represents around 15% of the EU’s GDP, was highlighted as a particular area where fairness and transparency are crucial. The consultation is positioned as an opportunity for stakeholders to raise concerns over rule complexity, compliance costs and potential avenues for simplification.

The FSR was introduced to safeguard competition within the EU by tackling distortions caused by non-EU subsidies, while keeping markets open to trade and investment. Its mechanisms apply across all sectors and economic activities, including acquisitions, public procurement and direct investment. The current review is the first in a three-year cycle of evaluations mandated under the Regulation.

Register Now: 2025 CFE Tax Symposium in Ghent on 18 September 2025

Registration is now open for the 2025 CFE Tax Symposium, taking place on Thursday, 18 September 2025, at the historic Oude Vismijn in Ghent, Belgium. Hosted in partnership with the Institute for Tax Advisors and Accountants Belgium, this year’s symposium, “Taxation in Transition: Compliance, Rights & Innovation in a High-Data World”, will convene policymakers, academics, and leading practitioners to examine the practical impact of the latest EU and international tax policy developments. 

The morning’s first panel will examine the EU & international tax policy landscape, moderated by CFE Director Aleksandar Ivanovski. Speakers will include Benjamin Angel (European Commission), Felicie Bonnet (OECD), Jorge Ferreras Guiterrez (Ministry of Finance, Spain), Helen Pahapill (Ministry of Finance, Estonia), and Prof. Dr. Georg Kofler (WU Vienna). They will discuss OECD Pillar Two implementation, EU simplification efforts, and broader cross-border trends.

After a networking lunch, the focus will turn to DAC and Taxpayers’ Rights, in a panel moderated by Eduardo Gracia Espinar (Ashurst EMEA, Spain) with panelists Reinhard Biebel (European Commission), Dr. Viktoria Wöhrer (WU Vienna, invited), and Philippe Vanclooster (ITAA), examining DAC recast, proportionality of sanctions, taxpayer rights, and the use of pre-populated tax returns.

The final panel on the interplay of AI, tax technology & indirect tax, chaired by Jeremy Woolf (Pump Court, UK), will bring together Jane Mellor (CIOT, UK), Nicholas Devillers (BDO, Luxembourg), and Petra Pospíšilová (Czech Chamber of Tax Advisers) to discuss AI-enabled compliance tools, real-time VAT reporting (MOSS, IOSS, VIDA), secure IT architecture, and ethical data use. 

Secure your place at the conference and register now!  More information and registration is available here.

Upcoming FISC Activities: Transatlantic Tax Issues & Cyprus Mission on OECD Reform

The European Parliament’s Subcommittee on Tax Matters (FISC) will hold a public hearing on 23 September 2025 to examine the “Tax implications of the Trump administration’s policies”. The session, taking place in Brussels from 15:45 to 17:00, will review recent shifts in U.S. tax policy under the Trump II administration and their potential impact on European businesses and the wider international tax landscape.

The hearing will centre on the implications of U.S. measures for the competitiveness of EU companies, particularly in light of global frameworks such as the OECD’s Pillar Two rules and the possible use of digital services taxes (DSTs) in the EU. Experts will also assess the broader consequences for international tax cooperation and consider potential EU-level policy responses designed to safeguard European interests.

In advance of the hearing, members of the FISC Subcommittee will undertake a delegation visit to Nicosia, Cyprus, from 15 to 17 September. Led by Chair Pasquale Tridico, the delegation will meet with representatives of government, parliament, private sector stakeholders, and civil society to discuss pressing international tax challenges. The agenda includes the implementation of the OECD two-pillar reform, exchange of tax information and anti-tax abuse measures, simplification of tax systems, competitiveness strategies, and the role of tax incentives and energy taxation.

Irish Tax Institute & Harvard Centre for International Development Global Tax Policy Conference: 23 & 24 October 2025

The 5th Global Tax Policy Conference, co-hosted by the Irish Tax Institute and the Harvard Center for International Development, will take place on 23–24 October 2025 in Dublin and is open for registration. This flagship event brings together a distinguished international lineup of policymakers, tax administration leaders, academics, and industry practitioners to examine the evolving landscape of global tax policy. The conference will open with a keynote address by Ireland’s Minister for Finance and Eurogroup President, Paschal Donohoe TD, setting the tone for two days of high-level dialogue.

Day one will feature sessions on the current state and future trajectory of global tax reform, with contributions from senior figures at the OECD, European Commission, and IRS. Discussions will explore the challenges of implementing complex global tax rules, the growing burden of corporate tax compliance, and the feasibility of a harmonised approach to dispute resolution. Speakers include Manal Corwin (OECD), Gerassimos Thomas (DG TAXUD), Danny Werfel (former IRS Commissioner), and representatives from the IMF, United Nations, and Tax Justice Network.

The second day will focus on the tax implications of global mobility and remote work, with a session dedicated to how tax systems can respond to digitalised forms of labour. Another panel will address how tax policy can support environmental and climate goals. The closing session, chaired by Harvard’s Jay Rosengard, will consider what the future of global taxation might look like, with emphasis on achieving consistency and certainty across jurisdictions. Across both days, the programme balances technical insight with practical implementation challenges, and offers a valuable opportunity for stakeholders to engage with emerging international tax dynamics.

More information and registration is available here.

The selection of the remitted material has been prepared by:
Dr. Aleksandar Ivanovski & Brodie McIntosh