CFE’s Tax Top 5 – 4 August 2025

Substantive negotiations on a proposed United Nations Framework Convention on International Tax Cooperation began this week, with the Intergovernmental Negotiating Committee convening for its first session from 4 to 8 August. A second session will meet take place from 11 to 15 August 2025. The formal and informal meetings focus on core commitments under the prospective Convention, including sustainable development, the fair allocation of taxing rights, and the prevention and resolution of tax disputes. The sessions are open to observers and broadcast via UN WebTV.

The first week’s agenda includes general statements, the election of officers, and discussions on draft commitments and issues notes prepared by the Chair. The second week will delve into two draft protocols: one concerning taxation of cross-border services in the digital economy, and another addressing dispute prevention and resolution mechanisms. According to the revised programme of work, the agenda reflects a dual focus on technical design and the broader policy implications of a multilateral tax agreement.

Coinciding with the opening of the negotiations, UN Secretary-General António Guterres announced the appointment of 25 new members to the UN Committee of Experts on International Cooperation in Tax Matters for the 2025–2029 term. The Committee, which functions independently of the Convention process but provides technical input through its normative guidance, includes experts from a wide range of countries and tax systems.

The work of the Committee and the Framework Convention process are seen as complementary pillars in the UN’s evolving tax agenda. While the Committee provides practical tools such as model laws, guidance on treaty negotiation, and administrative reforms, the Convention aims to establish a formalised intergovernmental platform.

US Executive Order on Revisions to the Reciprocal Tariff Regime 

On 31 July 2025, President Trump signed an Executive Order revising the “reciprocal tariff” framework first introduced on 2 April under Executive Order 14257. The earlier measures had imposed a 10% baseline tariff on all trading partners from 5 April, with higher country specific rates due to take effect from 9 April. The latest order extends the pauses on those elevated rates, originally set to begin on 9 July, pushing their implementation to 1 August and adjusts rates for selected countries based on the progress of bilateral negotiations.

Under the revised framework, countries not listed in Annex I of the Order revert to the 10% default rate, while Annex I countries face revised tariffs ranging generally between 25% and 50%, depending on trade deficit status and negotiation outcomes. Notably, Switzerland is subject to a 39% tariff, significantly higher than earlier estimates; India and Taiwan face duties of 25% and 20% respectively; Brazil is subject to a combined 50% tariff (including a country‑specific surcharge); and Canada’s rate is set at 35%.

The order emphasises that tariff rates can be modified downward for trading partners that demonstrate meaningful engagement, or upward in the case of retaliation or insufficient reforms. It also reiterates that the tariffs are justified under the International Emergency Economic Powers Act (IEEPA), citing the national security threat posed by the US trade deficit and non‑reciprocal trade practices.

The announcement has prompted mixed responses. EU officials reaffirmed that key exports—such as car parts—are not yet covered by reduced rates, while Switzerland signalled willingness to submit a “more attractive offer” to avoid the high duty. In parallel, the EU has agreed to suspend retaliatory tariffs on U.S. steel, aluminium and autos for six months, pending further clarification and negotiation with Washington.

Registration Now Open: 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 in Ghent, Belgium. Hosted in collaboration with the Belgian Institute for Tax Advisors and Accountants (ITAA), this year’s symposium will explore the theme of “Taxation in Transition: Compliance, Rights & Innovation in a High-Data World.” The event will bring together policymakers, academics, and leading tax professionals to examine the practical impact of major developments in international and EU tax policy.

The conference will open with welcome remarks from CFE President Piergiorgio Valente and ITAA President Bart Van Coile, followed by a keynote address from Filip Van de Velde, Head of the Belgian Tax Administration. The morning panel will set the scene with a discussion on the evolving EU and international tax policy landscape, including implementation of the OECD Pillar Two (GloBE) regime and emerging cross-border tax trends. Speakers will include representatives from the OECD, the European Commission,  Spanish and Estonian Ministries of Finance, and Prof. Georg Kofler.

In the afternoon, a second panel will focus on the recast of the Directive on Administrative Cooperation (DAC), taxpayer rights, and issues such as proportionality of sanctions and the legal status of pre-populated return systems. The final panel will examine the growing role of AI and technology in tax compliance, including real-time VAT reporting (MOSS/IOSS), secure IT architecture, and the ethical use of taxpayer data in digital systems. Contributions will come from senior tax officials, academics, and expert members of the CFE Technical Committees.

Save the date and secure your place! More information and registration is available here.

OECD Issues XML Schemas for Global Minimum Tax & Crypto-Asset Reporting

On 30 July 2025, the OECD published new XML Schemas and accompanying user guidance to facilitate the automatic exchange of information under the Global Minimum Tax (GMT) regime and the Crypto-Asset Reporting Framework (CARF).

In relation to Pillar Two, the OECD released the GloBE Information Return (GIR) Status Message XML Schema. This schema enables Competent Authorities to confirm whether GIR files received through the GloBE reporting system comply with agreed validation rules. The document includes the technical structure of the XML schema, user instructions, and the specific validation criteria for detecting file or record-level errors. This tool aims to support data quality in the exchange of GIR information as jurisdictions operationalise the Global Minimum Tax.

For crypto-asset reporting, the OECD published an updated version of the CARF XML Schema, incorporating technical revisions to support automatic exchanges of information under the framework endorsed in 2023. This update refines the schema approved in 2024 and includes clarifications relevant to both cross-border and, where applicable, domestic reporting obligations of Crypto-Asset Service Providers.

Additionally, the OECD has issued a new set of frequently asked questions addressing interpretative aspects of the CARF and the amended Common Reporting Standard (CRS). The FAQs are intended to support consistent and effective implementation across jurisdictions, offering further clarity on administrative and compliance issues associated with both standards.

EU Commission Publishes 2025 eInvoicing Country Factsheets with B2B Updates

The European Commission has released the 2025 edition of the eInvoicing Country Factsheets, providing an updated overview of national developments in electronic invoicing across the EU and selected EEA countries. Designed to support transparency and interoperability, the factsheets compile information on the legal frameworks, technical models, and monitoring systems in place across the 27 EU Member States and additional countries Norway, Iceland and Liechtenstein. This year’s edition also includes, for the first time, dedicated coverage of B2B eInvoicing developments, reflecting the growing scope of digital invoicing policy under the EU’s VAT in the Digital Age initiative.

Originally focused on Business-to-Government transactions following the 2014 eInvoicing Directive, EU policy has required public administrations since April 2020 to accept electronic invoices in compliance with the European Standard for contracts above the public procurement thresholds. The factsheets provide updates on how each jurisdiction has implemented these requirements and how their frameworks are adapting in anticipation of broader eInvoicing obligations under ViDA.

Each factsheet includes details on B2G, B2B, and B2C invoicing, national policy approaches, the use of Core Invoicing Usage Specifications (CIUS), and any real-time VAT reporting mechanisms in place. To ensure reliability, country representatives are invited to verify the factsheets, with a verification status indicated accordingly. Where verification is pending, the Commission notes that all entries are compiled with care to ensure accuracy and relevance.

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