International Tax Roundup June 2026: Pillar Two, EU, Rates
For U.S. companies with foreign operations — or foreign-owned U.S. businesses — international tax developments move fast and across many jurisdictions at once. This international tax roundup distills the early-to-mid June 2026 developments from primary sources: the OECD, the EU Court of Justice, and national governments and courts.
At SW Accounting & Consulting Corp, we advise Los Angeles area clients on cross-border tax. Below: OECD Pillar Two, the EU rulings, and notable country-level changes.
OECD: global minimum tax (Pillar Two) keeps maturing 🌐
- GIR XML schema fixes — the OECD released practical fixes to the GloBE Information Return (GIR) XML schema to support first filings. For in-scope multinational groups, the first GIR filings are an operational milestone — get data systems aligned to the schema.
- Updated 2026 consolidated commentary — the OECD released an updated consolidated commentary on the global minimum tax rules, the reference for interpreting the GloBE model rules.
- Transfer pricing of intragroup services — new OECD guidance on the transfer pricing of intragroup services, relevant to how multinationals price shared/centralized functions.
European Union: two important court developments ⚖️
- CJEU — transfer-pricing adjustments & VAT — the Court of Justice of the EU ruled on whether intragroup transfer-pricing adjustments can constitute consideration for a taxable supply of services for VAT, confirming a direct-link requirement between the supply and the consideration received. A reminder that TP adjustments can have VAT consequences, not just direct-tax ones.
- AG opinion — Parent-Subsidiary Directive anti-abuse — an Advocate General opined that an EU member state may deny the PSD withholding-tax exemption on outbound dividends where the immediate parent is the beneficial owner but the distribution is part of a wider abusive arrangement. AG opinions aren’t binding, but they often foreshadow the Court’s direction on beneficial ownership and treaty/directive shopping.
Country-level changes worth noting 🗂
| Jurisdiction | Development |
|---|---|
| Australia | Federal Budget 2026-27 bills introduced — negative gearing limits, CGT discount changes, a minimum tax, an AUD 250 working offset, and an AUD 1,000 standard work-expense deduction |
| Finland | Draft proposal to cut the corporate income tax rate from 20% to 18% and extend the loss carryforward period from 10 to 25 years (effective Jan 1, 2027 if enacted) |
| Germany | Federal tax court confirmed dividends paid to a U.S. “S corporation” qualify for 0% withholding tax; MOF issued a draft Annual Tax Act 2026 for stakeholder input |
| Panama | Economic substance requirements for foreign-source passive income became law |
| Hong Kong SAR / Greece / Indonesia / Philippines / Korea | IP capex deduction proposals (HK); broad new tax law (Greece); stricter preliminary refund rules (Indonesia); additional VAT clarification (Philippines); intensified corporate tax-evasion scrutiny (Korea) |
A German federal tax court confirming 0% withholding on dividends paid to a U.S. S corporation is a helpful data point for U.S.-owned structures with German operations — it supports treaty benefits for flow-through entities that are sometimes challenged abroad. As always, confirm the specific treaty position and documentation before relying on it.
Frequently asked questions
The GloBE Information Return (GIR) is the standardized report in-scope multinationals file under the OECD global minimum tax (Pillar Two). Practical fixes to its XML schema matter because first filings are an operational lift — your data systems must map cleanly to the required format.
They can. The CJEU addressed when an intragroup TP adjustment is consideration for a taxable supply of services, applying a direct-link test. Multinationals should consider VAT consequences of TP true-ups, not just direct tax.
No. An Advocate General’s opinion is advisory, not binding on the Court of Justice — but it often signals the Court’s likely direction, here on denying the PSD withholding-tax exemption in abusive dividend arrangements.
If you’re an in-scope multinational, Pillar Two GIR readiness is the near-term priority. Otherwise, watch jurisdiction-specific rate and substance changes (Finland, Panama) and treaty positions (Germany) that affect your structures.
How can SW Accounting help? 💼
At SW Accounting & Consulting Corp, we help LA-area clients with cross-border tax — Pillar Two / GloBE readiness, transfer-pricing documentation, treaty and withholding analysis, and foreign-entity reporting (including the U.S. forms that follow foreign operations). If your business or owners span borders, we’ll keep your positions aligned as the global rules evolve.
📩 Schedule a cross-border tax consultation
Disclaimer: This article is for informational purposes only and is not legal or tax advice. Always consult a qualified professional regarding your specific facts. Primary sources: OECD (GloBE Information Return XML schema, 2026 consolidated commentary, transfer-pricing guidance on intragroup services); Court of Justice of the European Union (TP adjustments/VAT ruling; Advocate General opinion on the Parent-Subsidiary Directive); Australian Federal Budget 2026-27 bills; Finland draft government proposal; German Federal Tax Court and Ministry of Finance draft Annual Tax Act 2026; Panama economic-substance law; and the respective tax authorities of Hong Kong SAR, Greece, Indonesia, the Philippines, and Korea.
