The Week in Tax edition for 7-11 September 2026 summarizes critical international tax developments. Highlights include the OECD’s public consultation on Amount B of Pillar One (simplified marketing and distribution profits), the EU Council’s agreement on the Unshell Directive (ATAD 3) targeting shell companies, US IRS guidance on clean energy tax credits under the Inflation Reduction Act, and a landmark Indian Supreme Court ruling on the taxability of offshore indirect transfers. Additional coverage includes UK-HMRC updated guidance on hybrid mismatch rules, Australian Taxation Office focus on trust distributions, and Brazilian transfer pricing documentation requirements.
Key Takeaways
- Pillar One Amount B Consultation: OECD seeks input on fixed remuneration for baseline marketing activities, potentially reducing transfer pricing disputes for distributors.
- EU Unshell Directive Finalized: Companies with minimal substance face presumption of tax avoidance, triggering reporting obligations and potential denial of treaty benefits.
- US Clean Energy Credits Clarified: IRS guidance on Sections 45X, 48C, and 45V provides certainty for manufacturers and hydrogen producers claiming advanced energy credits.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement