CFE’s Tax Top 5 – 20 October 2025

BRUSSELS | 20 OCTOBER 2025

 

G20 Meeting: Key OECD Tax Reports Presented to Finance Ministers


A G20 Finance Ministers and Central Bank Governors meeting took place on 15 and 16 October 2025 in Washington, DC, alongside the IMF and World Bank Annual Meetings under the South African Presidency. Discussions focused on the global economic outlook, financial stability, debt vulnerabilities, sustainable development financing, and strengthening multilateral coordination.

In preparation for the meeting, the OECD submitted several key reports on international tax policy developments, including updates on the implementation of the Two-Pillar Solution, a retrospective on ten years of the BEPS Project, and a new voluntary framework for the automatic exchange of information on immovable property.

Regarding tax matters, Ministers and Governors welcomed the submissions made by the OECD ahead of the meeting and called upon members to advance implementation of the agreed standards on transparency, dispute‑resolution and alignment of profits with value creation. G20 members agreed to intensify multilateral cooperation on tax avoidance and evasion, support the inclusive framework on the BEPS project, and examine the feasibility of expanding automatic exchange arrangements, thereby reinforcing tax as a core pillar of the global economic‑policy agenda.

OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (October 2025)

The OECD Secretary-General’s report provided G20 Finance Ministers and Central Bank Governors with a detailed update on progress made in international tax cooperation. The report noted substantial advancement on the implementation of the Two-Pillar Solution, with Pillar One’s Multilateral Convention on Amount A signed by 138 members of the Inclusive Framework in October, although ratification remains pending in many jurisdictions.

On Pillar Two, the report outlined momentum on global implementation of the Global Minimum Tax, with over 50 jurisdictions having already enacted or in the process of enacting legislation. Updates were also provided on capacity building efforts and the OECD’s support to developing countries via the G20/Inclusive Framework’s two-pillar strategy.

A Decade of the BEPS Initiative

To mark ten years since the launch of the BEPS Project, the OECD presented a retrospective report assessing its impact. The report found that the BEPS Project had achieved broad implementation of its minimum standards and had significantly reshaped the global tax landscape. Key milestones included the adoption of country-by-country reporting, the strengthening of transfer pricing rules, and a substantial increase in tax transparency.

The report noted that over 135 jurisdictions now participate in the Inclusive Framework, fostering unprecedented levels of international cooperation. Challenges remain, particularly in ensuring effective implementation in all jurisdictions and adapting to ongoing changes in the global economy. Nevertheless, the report concluded that the BEPS Project had led to measurable progress in tackling tax avoidance and aligning profits with value creation.

Framework for the Automatic Exchange of Readily Available Information on Immovable Property for Tax Purposes

As a new voluntary initiative, the OECD launched a Framework to support the automatic exchange of information on immovable property. The framework aims to assist tax administrations in accessing ownership information about real estate held by non-residents, an area often vulnerable to tax evasion and illicit financial flows. Participating jurisdictions would collect and exchange readily available data from government sources such as land registries, tax records and other public databases. The intention is to provide greater transparency and support compliance by foreign property owners, complementing existing initiatives such as the Common Reporting Standard and Beneficial Ownership Transparency. The framework is presented as a flexible, modular tool that jurisdictions can adopt according to their domestic capabilities and policy priorities.

UN Tax Committee 31st Session: 21 to 24 October 2025


The United Nations Committee of Experts on International Cooperation in Tax Matters will hold its thirty-first session in Geneva from 21 to 24 October 2025.

The Committee is expected to discuss the role of taxation in achieving the Sustainable Development Goals (SDGs), focusing on aligning tax policy with sustainable development outcomes and enhancing domestic resource mobilisation, particularly in developing countries. Members will also consider updates to the United Nations Model Double Taxation Convention between Developed and Developing Countries, reflecting developments in international tax standards.

Another key item on the agenda will be the review and potential update of the United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries, a foundational resource for treaty negotiators. In addition, procedural issues concerning the Committee’s operations and potential new areas of work will be considered under its evolving work programme.

Further details and background materials are available via the official UN session page.

Inter-Parliamentary Committee Meeting on the Taxation of the Digitalised Economy


At the recent Inter-Parliamentary Committee Meeting of the European Parliament’s FISC Committee, policymakers and experts gathered to discuss the taxation of the digitalised economy. The debate centred on the continued use of Digital Services Taxes versus advancing a multilateral solution through the OECD. Speakers expressed views on how to address profit shifting, ensure fair competition, and maintain Europe’s global competitiveness in a rapidly digitalising world.

Ms María José Garde, Director General of Taxation at the Ministry of Finance, Spain, explained Spain’s reasoning for maintaining a measure of a temporary nature, given the limitations of current international tax rules, which rely on physical presence and fail to account for user-driven value creation. Spain’s DST was presented as a successful, non-discriminatory model generating increasing revenue and applicable to both domestic and foreign entities. Broader concerns were raised over digital multinationals’ ability to minimise tax liabilities while relying heavily on public infrastructure, highlighting issues of social fairness and revenue adequacy.

Other participants voiced reservations about DSTs, citing the risks of overburdening traditional businesses and harming competitiveness. Speakers from Sweden and Greece pointed to Europe’s lack of major technology companies compared to the United States and suggested that regulatory burdens and tax uncertainty might be contributing factors. Malta called for maintaining a balance between fairness and global competitiveness, particularly from the perspective of smaller member states. Stability and clarity in tax systems were widely seen as crucial for attracting investment. The OECD’s Pillar One was affirmed by several speakers, including Benjamin Angel, Director, Direct Taxation, European Commission, as the best path toward a long-term, consensus-based solution.

Looking to the future, many speakers stressed the need for coordinated action, both within Europe and globally. Although DSTs may serve as temporary measures, the shared objective is a sustainable, globally agreed framework that aligns taxing rights with economic activity. Calls were made for European institutions and national parliaments to exert pressure for timely implementation. The meeting concluded with broad agreement on the importance of digital tax reform, acknowledging the complexity of the task and the need for continued dialogue and cooperation.

CFE Opinion Statement on EU VAT Rules for Travel & Tourism


CFE Tax Advisers Europe has published an Opinion Statement in response to the European Commission’s consultation on VAT rules applicable to the travel and tourism sectors, with a focus on the Tour Operators’ Margin Scheme (TOMS). CFE considers that TOMS no longer achieves its objectives of simplification and neutrality, and instead creates legal uncertainty and administrative burdens for businesses operating across the EU.

The statement identifies key concerns, including inconsistent application of the scheme across Member States, denial of input VAT deduction in business-to-business transactions, and unworkable requirements to calculate margins on a transaction-by-transaction basis. Difficulties also arise in the treatment of in-house services, prepayments, and identifying the status of customers at the time of sale.

CFE recommends that TOMS be limited to business-to-consumer transactions, with business-to-business supplies falling under normal VAT rules to preserve input VAT recovery. It also proposes excluding MICE services, introducing opt-outs for businesses offering travel services incidentally, and replacing or complementing TOMS with a one-stop-shop (OSS) mechanism for cross-border VAT compliance.

Further proposals include ensuring equal VAT treatment for non-EU travel agents, simplifying VAT for multi-country travel through a single Member State designation, and harmonising rules on margin calculation, prepayments, and loss-making transactions. Clearer guidance is also sought for packages involving both in-house and purchased services, and for B2B transactions involving non-EU suppliers.

CFE concludes that reform is urgently needed to restore fairness, consistency and administrability in the VAT treatment of travel and tourism. The Commission is encouraged to prioritise neutrality, legal certainty, and simplification in designing a modernised VAT framework for the sector.

EU Expands Tax Cooperation Agreements with Andorra, Lichtenstein, Monaco & San Marino


On 13 October 2025, the European Commission announced the signing of four amending protocols to the EU’s existing agreements on the automatic exchange of financial account information (AEOI) with Andorra, Liechtenstein, Monaco and San Marino. These agreements, initially concluded between 2015 and 2016, aim to align the tax cooperation frameworks of these neighbouring jurisdictions with evolving EU and OECD standards on financial transparency. The revised protocols expand the scope of reportable financial information to include new categories such as electronic money products and central bank digital currencies, reflecting technological developments in the financial sector.

In addition to the broadened scope, the protocols reinforce due diligence and reporting obligations for financial institutions operating in the relevant jurisdictions. The measures also enhance safeguards to ensure that data exchanged remains protected in accordance with the EU’s high standards on privacy and data protection. These developments mirror updates in the EU’s Directive on Administrative Cooperation (DAC), particularly as regards digital assets and new financial instruments, and they reflect parallel updates in the OECD’s Common Reporting Standard (CRS).

The revised agreements are intended to take effect from 1 January 2026, subject to ratification by the relevant parties. The Commission highlighted the significance of these reforms given the close economic and financial ties between the four jurisdictions and EU Member States. The move is part of the EU’s broader strategy to close potential tax transparency gaps, particularly where cross-border arrangements could otherwise escape effective oversight. The Commission also confirmed that negotiations are continuing with Switzerland, with a view to reaching a similar updated agreement.


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