CFE’s Tax Top 5 – 26 January 2026

BRUSSELS | 26 JANUARY 2026

OECD Tax Consultation on the Global Mobility of Individuals

On 20 January 2026, the OECD held its public consultation meeting on the Global Mobility of Individuals, following a submission process carried out in late 2025 as part of the OECD Inclusive Framework’s evidence-based work on the tax implications of evolving working patterns.

The consultation reflected the growing recognition that cross-border remote working, short-term stays and more flexible employment models create real challenges under existing domestic rules and tax treaty concepts, both for taxpayers and employers, as well as for tax administrations seeking workable and proportionate compliance solutions.

Aleksandar Ivanovski, Director of CFE Tax Advisers Europe, and Brodie McIntosh, Tax Policy Analyst, represented CFE at the consultation meeting. The agenda covered a wide range of issues connected to modern mobility, including economic trends shaping cross-border work, corporate income tax implications (including permanent establishment risk), the interaction with social security frameworks, and employment income taxation questions such as residence, taxing rights and compliance burdens. The discussion also highlighted how emerging work patterns, including digital nomadism and platform-based work, raise practical questions around tax certainty, administrability and coordination across jurisdictions

CFE’s participation built on our written contribution, Opinion Statement CFE 5/2025, submitted in response to the OECD consultation. In our submission, we emphasise the increasing complexity faced by individuals and employers navigating cross-border mobility in good faith, including uncertainty in the application of residence tests, treaty rules and employment income provisions, and the resulting risks of double taxation and disproportionate compliance obligations. We support the OECD’s work in this area and encourage the development of clearer, more coherent and administrable guidance, with a focus on proportionality in low-risk and temporary mobility cases and strengthened mechanisms for coordination, dispute prevention and dispute resolution.

GTAP Chairman, Piergiorgio Valente, also participated in the consultation, representing the Global Tax Advisers Platform (GTAP), bringing forward the perspective of tax professionals across multiple global regions. GTAP operates as an umbrella body for 65 tax institutes and professional organisations worldwide, including CFE Tax Advisers Europe, the Asia Oceania Tax Consultants’ Association (AOTCA) and the West African Union of Tax Institutes (WAUTI). In his intervention, Piergiorgio presented six priority actions aimed at improving legal certainty and reducing compliance burdens for mobile workers and employers, including internationally aligned safe-harbour thresholds for cross-border remote work, modernisation of treaty tie-breaker rules on tax residence, and stronger treaty protection for individuals benefiting from preferential tax regimes. He also highlighted the need for more effective dispute prevention and resolution mechanisms for residence conflicts, common administrative approaches for cross-border remote work, and improved accessibility and consistency of national guidance.

CFE and GTAP will continue to contribute practice-based insights to support international tax certainty for globally mobile individuals and employers.

US Signals Tariff Pause as Greenland Dispute Raises Wider EU-US Trade Uncertainty 

Trade tensions eased late last week after US President Donald Trump said the United States would not proceed with additional tariffs on European countries that had been scheduled to take effect on 1 February, following the announcement of a “framework” understanding with NATO relating to Greenland and wider Arctic security. Trump described the arrangement as a “concept of a deal” and indicated that further discussions would follow.

The tariff threat had been positioned as leverage in the context of rising tensions over Greenland. Trump had previously indicated that tariffs could be applied to a group of European countries, including Denmark and other major allies, until an agreement was reached, creating the prospect of a sudden escalation in transatlantic trade measures. The situation prompted strong reactions in Europe, with EU leaders and national governments signalling that they were prepared to respond if tariffs were imposed, and framing the issue as both an economic and geopolitical challenge for the EU and NATO.

Although the immediate tariff escalation has been paused, the episode has reinforced concerns over the predictability of EU–US trade relations where tariff measures may be introduced, withdrawn, or revived in response to broader political disputes. In parallel, European policymakers have continued to highlight the importance of reducing strategic dependencies, with energy security increasingly referenced as part of Europe’s wider resilience agenda. Recent discussions among North Sea countries on accelerating offshore wind development and associated cross-border grid infrastructure have been framed as supporting longer-term independence and stability, particularly as the EU reduces reliance on Russian gas while imports of liquefied natural gas from the US have grown substantially. While not a direct trade countermeasure, this approach signals that the EU’s response to geopolitical pressure may increasingly combine tariff readiness with broader policy initiatives aimed at limiting economic vulnerabilities.

OECD Publishes Updated Transfer Pricing Country Profiles

The OECD has released an updated set of Transfer Pricing Country Profiles, reflecting jurisdictions’ latest approaches to key transfer pricing principles and how closely these align with the OECD Transfer Pricing Guidelines. The country profiles provide a structured overview of areas such as the arm’s length principle, transfer pricing methods and comparability analysis, treatment of intangible property and intra-group services, cost contribution arrangements, documentation requirements, dispute resolution mechanisms and the use of safe harbours or other implementation measures.

The OECD confirmed that the latest update represents the fourth batch of updated transfer pricing country profiles, covering eight jurisdictions: Bosnia and Herzegovina, Brazil, Costa Rica, Croatia, Greece, Iceland, Korea and Norway. These updates are intended to reflect current legislation and administrative practice, and may be relevant for tax advisers supporting European groups with cross-border structures or operating footprints in these jurisdictions.

This round of updates also continues the OECD’s approach of expanding the profiles beyond core transfer pricing concepts, by including new insights linked to developments under Pillar One. In particular, the updated profiles include jurisdiction-specific information relating to the simplified and streamlined approach for baseline marketing and distribution activities (Amount B), which may support advisers in evaluating how jurisdictions interpret or operationalise simplification measures for routine distribution arrangements.

In addition, the OECD materials highlight continued attention to the transfer pricing treatment of hard-to-value intangibles, reflecting how jurisdictions may implement the approach described in the OECD Transfer Pricing Guidelines. For groups with significant intangible-driven value chains, this information may assist advisers in identifying jurisdictions where administrative practices may be more developed or specific in relation to valuation uncertainty and ex post outcomes.

EU Parliament’s FISC to Examine Single Market Tax Barriers & “Cost of non-Europe”in Tax Harmonisation

The European Parliament’s Subcommittee on Tax Matters, FISC, will hold its next meeting tomorrow on Tuesday, 27 January 2026, featuring a public hearing on “Tackling tax obstacles in the Single Market”. The hearing will bring together external experts to discuss with FISC Members how remaining tax-related obstacles and distortions continue to affect cross-border activity, and what practical solutions could be pursued within the existing EU legal framework. The discussion follows on from the European Commission’s Single Market Strategy presented in May 2025, which aims to strengthen and simplify the internal market, but does not explicitly address tax barriers arising from the continued coexistence of 27 national tax systems.

The meeting will also include a presentation of the European Parliamentary Research Service study “The future of EU tax policy harmonisation – Cost of non-Europe report”, which examines the economic and administrative costs created by fragmented national tax rules and highlights four areas where divergent approaches may undermine the Single Market: wealth taxation, crypto assets taxation, digitalisation of tax administration, and tax compliance burdens.

UN International Tax Cooperation Convention: Key Updates Ahead of February 2026 Negotiations

    The United Nations has published key practical information and documentation ahead of the Fourth Session of the Intergovernmental Negotiating Committee for the United Nations Framework Convention on International Tax Cooperation. The session will take place at UN Headquarters in New York from 2–3 and 5–13 February 2026, and will focus on advancing negotiations on the framework convention and related early protocols.

    A number of key documents have been released to support the Fourth Session, including:

    • a draft programme of work.
    • a Co-Leads’ draft framework convention template under Workstream I on the Framework Convention.
    • a draft options paper on Taxation of Services, under Workstream II.
    • a concept note on dispute prevention and resolution under Workstream III.
    • a background note examining the policy trade-offs between gross-basis and net-basis taxation, including efficiency and equity considerations.

    Ahead of the session, the UN will also host a Multi-Stakeholder Dialogue on 29 January 2026 via Zoom, providing an update on progress in the negotiations and a look ahead to the February meeting. Proceedings of the Fourth Session will be available through UN Web TV, with live and archived coverage in all six official UN languages.

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