Gli Opinion Statement CFE sul pacchetto UE di semplificazione delle imposte dirette (Omnibus e rifusione DAC), la consultazione ONU verso la quinta sessione negoziale, i nuovi dazi USA su 60 partner commerciali, le osservazioni CFE sul Capitolo VII delle Linee guida OCSE sui prezzi di trasferimento e le statistiche fiscali OCSE 2026.
CFE Publishes Opinion Statements on the EU Direct Tax Simplification Package
CFE Tax Advisers Europe released two Opinion Statements addressing the European Commission's proposals for a Direct Taxation Omnibus Directive and for a Recast of the Directive on Administrative Cooperation. Both proposals sit at the heart of the Commission's tax simplification package, which aims to cut administrative burdens and modernise the EU direct tax framework. On the Omnibus, CFE welcomes the removal of minimum holding requirements under the Interest and Royalties and Parent-Subsidiary Directives and the move to taxpayer self-assessment for withholding tax relief. It questions the proposed eight-year deferral before the new procedures apply and raises concerns about extending the General Anti-Abuse Rule to Pillar Two top-up taxes, which could unsettle the agreed GloBE framework. On the DAC Recast, CFE supports consolidating the Directive and its amendments into a single instrument, welcomes the removal of Category A generic hallmarks and the extension of the reporting deadline from 30 to 90 days, and reiterates its preference for a taxpayer-default reporting model in light of recent Court of Justice case law on legal professional privilege.
UN Multi-Stakeholder Consultation Ahead of the Fifth Negotiating Session
The United Nations convened a virtual multi-stakeholder consultation on 28 July 2026 to update stakeholders on negotiations for the proposed UN Framework Convention on International Tax Cooperation and its two early protocols. The session reviewed progress to date, presented the latest negotiating texts and set out the outlook ahead of the Fifth Session of the Intergovernmental Negotiating Committee, held at UN Headquarters in New York from 3 to 13 August 2026. The protocols are intended to become the first substantive instruments under the new UN framework, covering international tax governance, cross-border taxation and dispute prevention and resolution.
United States Imposes New Tariffs on 60 Trading Partners
On 23 July 2026 the US President announced new Section 301 tariffs on imports from 60 economies, following investigations by the Office of the United States Trade Representative into the enforcement of bans on goods produced with forced labour. The measures replaced the temporary Section 122 tariffs and took immediate effect. Rates of 10% apply to economies with forced labour import prohibitions or equivalent commitments, including the European Union, Canada, Mexico and the United Kingdom, while 12.5% applies to the remaining investigated economies. Product-specific exemptions cover certain raw materials and goods that cannot be sourced domestically in sufficient quantities, and a textile mechanism allows a set volume of apparel imports to enter free of the new duties. Several trading partners publicly criticised the measures.
CFE Submission on the Revision of Chapter VII of the OECD Transfer Pricing Guidelines
On 22 July CFE published an Opinion Statement responding to the OECD consultation on proposed revisions to Chapter VII of the Transfer Pricing Guidelines, which deals with intra-group services. CFE welcomes the modernisation effort and argues that the benefit test should be assessed on the facts known when the service is performed, rather than with hindsight. It recommends that shareholder activities be characterised by their substance and the benefit provided, not by the organisational level at which they are carried out. CFE supports a principles-based approach to charging mechanisms and allocation keys that allows reasonable approximations, warns against documentation requirements becoming a de facto mandatory checklist, and backs retaining the simplified approach and its 5% mark-up for low value-adding services, provided it is not treated as a benchmark elsewhere.
OECD Publishes 2026 Corporate Tax Statistics and Updated BEPS Action 5 Peer Reviews
The OECD released the 2026 edition of its Corporate Tax Statistics together with revised peer reviews of preferential tax regimes under BEPS Action 5. The statistics show corporate income tax revenues remaining historically high in 2023, averaging 17.3% of total tax revenues and 3.5% of GDP across 135 jurisdictions, with large multinational groups contributing an average of 44.5% of corporate tax revenues in the 60 jurisdictions supplying Country-by-Country Reporting data. Average statutory rates stayed broadly stable at 21.2%. The anonymised CbCR dataset now covers almost 9,400 multinational groups. On Action 5, the Inclusive Framework approved updated results for 13 preferential regimes: six were found not harmful, including Japan's new IP box assessed as consistent with the nexus approach, while seven remain under review.
Fonte: CFE Tax Advisers Europe