The OECD Forum on Tax Administration has published a Global Minimum Tax Implementation Toolkit, providing a structured roadmap to support jurisdictions in implementing and administering the Pillar Two global minimum tax. The Toolkit is intended for tax administrations and policymakers and draws on t
BRUSSELS | 4 MAY 2026
OECD Publishes Global Minimum Tax Implementation Toolkit
The OECD Forum on Tax Administration has published a Global Minimum Tax Implementation Toolkit, providing a structured roadmap to support jurisdictions in implementing and administering the Pillar Two global minimum tax. The Toolkit is intended for tax administrations and policymakers and draws on the experience of early adopters, as well as input from business and other stakeholders, with the objective of promoting consistent and efficient application of the GloBE rules while limiting administrative and compliance burdens. The Toolkit is organised into five modules covering key stages of implementation. These include: identifying in-scope multinational enterprise (MNE) groups and estimating potential revenues; legal implementation of the rules; organisational and operational planning; the design of compliance procedures; and the exchange of information, including use of the GloBE Information Return (GIR). It distinguishes between a pre-implementation phase focused on impact assessment and legislative design and an implementation phase, which addresses operational readiness, IT systems, and administrative processes. A central feature is the provision of practical guidance on establishing a domestic compliance framework for the collection of top-up tax. The Toolkit emphasises the importance of coordinated approaches across jurisdictions, including reliance on common data sources such as country-by-country reporting, the development of risk-based compliance strategies, and the use of automatic exchange of information mechanisms under the GIR framework. The document also highlights the need for alignment with the GloBE Model Rules, Commentary and Administrative Guidance, noting that jurisdictions have adopted different legislative techniques (including cross-reference, repetition, and rewrite approaches) to incorporate the rules into domestic law. It further outlines mechanisms to ensure ongoing consistency, including the use of secondary legislation, interpretative clauses, and administrative guidance. The Toolkit forms part of broader OECD work to support the implementation of the global minimum tax and is expected to be updated over time as further implementation experience is gained.
ECOFIN to Advance VAT Fraud Enforcement & Tax Cooperation Measures
This week, EU Finance Ministers will meet in their configuration at ECOFIN, and are expected to agree a general approach on a proposed regulation granting the European Public Prosecutor’s Office and the European Anti-Fraud Office access to EU-level VAT information. The initiative is intended to strengthen administrative cooperation and improve the detection, investigation, and prosecution of cross-border VAT fraud, which remains a significant source of revenue loss within the EU. The discussions take place in the broader context of ongoing EU efforts to combat tax fraud, evasion, and avoidance through enhanced transparency and information exchange between tax authorities. Existing frameworks, such as the Directive on Administrative Cooperation (DAC) and VAT administrative cooperation rules, already facilitate cross-border data sharing, joint audits, and coordinated enforcement actions. The proposed extension of access to EU-level VAT data for EPPO and OLAF represents a further step in strengthening enforcement at EU level. The Council will also hold a policy debate on the market integration and supervision package, which includes legislative proposals aimed at further developing capital markets integration and supervisory frameworks within the EU. While primarily focused on financial markets, the package is part of the broader savings and investment union agenda, which may have indirect implications for tax systems and cross-border investment flows. In the area of economic recovery, the Council is expected to adopt implementing decisions under the Recovery and Resilience Facility, including the approval of amended national recovery and resilience plans. These plans continue to support Member States’ reform and investment agendas, including measures with tax policy and administration dimensions. Finally, the Presidency and the European Commission will report on the outcomes of the G20 Finance Ministers and Central Bank Governors meeting of 16 April 2026, followed by an exchange of views among ministers.
OECD Issues Practical Guide on Investment Tax Incentives
The OECD has published a Practical Guide to Investment Tax Incentives, providing policymakers with practical tools to improve the effectiveness and value for money of tax incentives, particularly in developing and emerging economies. The report emphasises that while tax incentives are widely used to attract investment, their performance is mixed and they can entail significant fiscal costs, economic distortions and administrative complexity if not properly designed. The guide takes a lifecycle approach, covering the stages of conception, design, implementation, monitoring and evaluation. It highlights the importance of clearly identifying policy objectives and underlying market failures before introducing incentives, alongside conducting ex-ante assessments of expected costs and benefits and ensuring coherence with broader policy frameworks. In relation to design, the OECD indicates that expenditure-based incentives, such as accelerated depreciation and tax credits, are generally more effective in stimulating additional investment than income-based incentives, which can generate windfall gains and increase risks of tax avoidance. The report also stresses the need to balance targeting and simplicity, limit excessive generosity, and link incentives to measurable outcomes. On implementation, the guide underlines the importance of transparent and predictable procedures, including the use of self-assessment mechanisms where appropriate, to reduce compliance costs and administrative burdens. It also highlights the need for improved data collection, monitoring and evaluation frameworks to assess effectiveness and inform potential reform or removal of incentives that do not deliver expected benefits.
Tax Policy Under Pressure: CFE Forum Highlights Growing Complexity, Fragmentation & Compliance Demands
On 23 April, the CFE Forum 2026 was held in in Brussels, examining how tax systems are adapting to increasing structural pressures arising from geopolitical developments, digitalisation, and expanding regulatory frameworks. Across three panels, discussions focused on simplification, international coordination, the interaction of tax systems, and evolving compliance and ethical obligations. Panel 1: Global Pressures on Tax Policy In the first panel, Benjamin Angel (European Commission) outlined the forthcoming Omnibus simplification package, aimed at reducing compliance burdens by removing rules rather than amending them, including through changes to multiple directives and the reduction of overlapping reporting obligations. Edwin Visser (PwC) observed that complexity often arises from Member State implementation, particularly through “gold plating”, while Helen Pahapill (UN Framework Convention on International Tax Cooperation) noted that removing EU provisions does not ensure their elimination at domestic level. Pillar Two was a central topic of discussion. Edwin Visser described the concept of minimum taxation as sound in principle but complex in design, raising questions about whether simplification is achievable without structural changes. Daniel Bunn suggested similar policy objectives might be achieved through less complex mechanisms, while Benjamin Angel emphasised that Pillar Two establishes a global floor on tax competition and contributes to predictability. Speakers also noted evolving revenue expectations, particularly in relation to the United States, and ongoing competitiveness considerations. Helen Pahapill highlighted intra-EU dynamics and concerns from developing countries regarding the allocation of taxing rights. On international coordination, Helen Pahapill described progress toward a UN framework convention targeted for adoption in 2027, noting differences between OECD and UN processes. Edwin Visser highlighted risks of geopolitical fragmentation and treaty overrides, while Daniel Bunn cautioned that expanded source-based taxation could affect cross-border trade. Benjamin Angel indicated that while the EU continues to prioritise multilateral solutions, alternative approaches may be required in their absence. Panel 2: Cross-Border Coherence – Direct and Indirect Tax & Transfer Pricing The second panel focused on the interaction between VAT, transfer pricing and corporate taxation. Trudy Perié (CFE Indirect Taxes Subcommittee) noted that these interactions increasingly generate uncertainty, compliance burdens and litigation risk, raising questions about coherence. She explained that transfer pricing adjustments trigger VAT only where a taxable supply, consideration, and a direct link exist, distinguishing between compensating adjustments and authority-imposed adjustments. Jeremy Woolf (Pump Court Tax Chambers) emphasised that this is primarily a question of legal characterisation. Jan-Willem Kunen (Loyens & Loeff) highlighted the importance of inter-company agreements in defining functions, risks and pricing mechanisms, including year-end adjustments. Trudy Perié noted practical differences depending on VAT recovery positions, while Fernando Matesanz (International VAT Association) pointed to inconsistencies between VAT and transfer pricing frameworks across jurisdictions. The panel discussed recent ECJ case law, noting that contractual framing is often decisive in determining VAT outcomes. Profit split arrangements were identified as an area of uncertainty. Jan-Willem Kunen and Fernando Matesanz noted that such arrangements may be characterised either as profit allocations or reciprocal services, with implications for VAT treatment. Jeremy Woolf indicated that outcomes remain fact-dependent and may give rise to disputes. Margaux Smets (FOD Financiën, Belgium) illustrated the interaction between transfer pricing adjustments and withholding tax, noting that excess payments may be disallowed for corporate tax purposes while also being subject to withholding tax at domestic rates where treaty benefits do not apply. Speakers emphasised the cumulative impact of such adjustments and the importance of consistency between transfer pricing documentation and treaty positions, particularly in relation to beneficial ownership. Panel 3: DAC, AMLA and the Evolving Compliance Landscape The third panel addressed compliance, transparency and professional ethics. Henrik Paulander (European Commission, DG TAXUD) outlined the DAC recast, which aims to consolidate directives, reduce duplication and improve the usability of reported information. Johan Barros (Accountancy Europe) noted that the volume of reporting raises questions about the capacity of tax administrations to process data effectively, while Aleksandar Ivanovski (CFE Tax Advisers Europe) emphasised the need for proportionality and clarity to ensure legal certainty. Raluca Pruna (European Commission, DG FISMA) described the new AML framework as a shift toward fully harmonised rules supported by AMLA, aimed at addressing supervisory gaps and inconsistencies across Member States. She noted that the framework extends to non-financial sectors, including tax advisers, and introduces increased compliance obligations. Henrik Paulander and Aleksandar Ivanovski highlighted implications for firms, particularly smaller practices, including mandatory compliance roles and the need to adapt governance structures. On professional ethics, Ken Siong (IESBA) outlined the Global Standard on Tax Planning, including the credible basis and reputational tests, which require practitioners to assess both the technical robustness of tax positions and their broader implications. He noted that the standards aim to support consistent professional judgment and enhance public trust. The panel also addressed the use of artificial intelligence in tax practice. Ken Siong highlighted risks including automation bias and variability in outputs, while Raluca Pruna noted that under the EU AI Act, professionals must ensure AI literacy and remain responsible for outputs. Eduardo Gracia Espinar (Ashurst) emphasised that AI outputs should be treated as draft work subject to review. Speakers also addressed confidentiality and data use, noting the need for explicit client consent when using AI systems, and discussed the NOCLAR framework as a structured approach to addressing non-compliance, with external reporting as a last resort. Overall, discussions reflected increasing complexity and interdependence across tax systems, alongside expanding regulatory expectations. Speakers emphasised the importance of coordination, consistency and professional judgment in navigating these developments.
New OECD Blog on the Use of Artificial Intelligence in Tax Administration
Last week, the OECD published a blog post outlining the evolution and current use of artificial intelligence (AI) in tax administration, highlighting the shift from early mechanical tools to advanced data-driven systems. Tax administrations have become highly data-rich institutions and are increasingly adopting AI and data science tools as part of broader digital transformation efforts aligned with Compliance Risk Management principles and the OECD’s Tax Administration 3.0 vision of “seamless taxation”. According to the OECD’s International Survey on Revenue Administration (ISORA), over 90% of surveyed jurisdictions in 2023 had implemented or were implementing AI solutions, compared to just over 40% in 2018. AI is being applied across a range of functions, most prominently in fraud and evasion detection, where machine learning techniques are used to identify patterns and anomalies in large datasets. It is also widely used in risk assessment processes, supporting predictive modelling and the identification of non-compliance risks. In addition, AI-powered tools, including virtual assistants and generative AI applications, are increasingly used to improve taxpayer services and internal administrative processes, such as case prioritisation and resource allocation. The OECD highlights that while AI offers significant potential to improve efficiency, accuracy and taxpayer experience, it also introduces new risks. The blog emphasises the importance of ensuring fairness, proportionality, and the protection of taxpayer rights, noting that the use of predictive analytics raises additional considerations where decisions are based on inferred future behaviour rather than past actions. To address these challenges, the OECD Forum on Tax Administration has established a project group under its Tax Administration 3.0 initiative to support the development of trustworthy AI in tax administration. This work builds on the OECD Principles on Trustworthy AI and aims to translate high-level principles into practical tools and frameworks tailored to tax administration contexts.
The selection of the remitted material has been prepared by: Dr. Aleksandar Ivanovski & Brodie McIntosh
Fonte: CFE Tax Advisers Europe. Pubblicazione originale del 2026-05-04.