Tax Trends And Developments For MNEs In 2026

As 2025 nears its end, we are pleased to present our annual tax bulletin offering a forward-looking analysis of the expected tax landscape for multinational enterprises (MNEs) in 2026 including valuable tips and takeaways.

In this bulletin, our specialists provide insights on both general and specific tax trends and developments impacting MNEs at international and European level, as well as in our four home markets, the Netherlands, Belgium, Luxembourg, and Switzerland.

As some of the identified trends and developments vary by country, the bulletin highlights the main topics relevant to each jurisdiction rather than repeating common themes across all countries.

We trust this bulletin provides valuable insights to help you navigate the tax landscape in 2026.

Please download the full version of the tax update or read the online version below.

Tax trends and developments for MNEs in 2026

The future tax landscape

In 2025, the trend that important new tax legislation originates at an international level, rather than a domestic level, continued. We expect that this trend will continue in 2026 and future years.

The OECD continues to be a large contributor to new international tax legislation with, for example, new Pillar Two legislation and an update to Chapter VII of the Transfer Pricing Guidelines expected in 2026. In addition, the European Commission is expected to release new tax proposals in 2026, to the benefit of taxpayers. This legislation will be part of initiatives to improve the EU's competitiveness and simplify tax rules, including the EU Blue Carpet Initiative, the Clean Industrial Deal and the "Omnibus on Taxation" package. This is a welcome change after years of new tax legislation introduced by the EU with a view to regulating taxpayers (e.g., the Anti-Tax Avoidance Directive, ATAD). Beyond 2026, areas to watch are the pending BEFIT proposal, the potential reactivation of the EU's (2018) proposal to introduce a Digital Services Tax (DST) and new (tax) measures to generate revenue to fund the EU's own budget.

At a national level, things have been relatively quiet on the legislative front in the Netherlands. The Dutch annual budget was "policy-light" in 2025, in anticipation of the elections that were held recently (a new Dutch government is currently being formed). In Belgium, the new federal government formed in 2025 is executing an agreement that sets the stage for significant changes in tax policy to enhance Belgium's competitiveness and to foster its economy. In both Switzerland and Luxembourg, tax legislation continues to be rather stable, outside the implementation of Pillar Two.

In all our home jurisdictions we have seen a sharp increase in tax controversy, including both tax audits and disputes, particularly, in the field of transfer pricing. We expect this trend to continue in 2026 and future years as well. The number of mutual agreement procedures (MAP) lodged has remained high. The same goes for multi-jurisdictional audits. Furthermore, a new dimension has been introduced to tax disputes by taxpayers, namely, the claim that (EU) secondary tax legislation breaches their fundamental rights under primary EU law. It will be interesting to see how the European Court of Justice (CJEU) will address such arguments in pending proceedings on the Pillar Two Directive and the solidarity contribution from oil & gas companies under an EU Regulation.

Finally, expectations regarding (new) tax legislation are closely linked to (geo)political developments. A particular area to monitor in 2026 is the implementation of the trade deal negotiated between the US and the EU about custom duties & tariffs and further negotiations in this respect.

The International landscape

Introduction

As the international tax environment continues to evolve, 2026 is expected to bring significant changes for MNEs. While much of the focus at the international level will likely remain on the ongoing discussions about the "Side-by-Side" system (Side-by-Side system) in respect of Pillar Two, the landscape will also be shaped by the recent publication of the 2025 Update to the OECD Model Treaty, with important implications for dispute resolution, home office permanent establishments (PE), and associated enterprises. In addition, the tax landscape in 2026 is expected to be impacted by the
growing importance of MAP as a strategic tool for managing cross-border tax risk, the shifting dynamics of digital taxation amid stalled Pillar One negotiations and a proliferation of unilateral digital services taxes (DSTs), and the new EU-US trade deal affecting transatlantic business.

Each of these topics is explored in more detail in the following sections to help you anticipate and engage with the issues most likely to shape your 2026 tax strategy.

Pillar Two: Side-by-Side system and other developments

Upon the global agreement on Pillar Two (GloBE Rules), the EU took a frontrunner role in the coordinated implementation of these rules, by way of the Pillar Two Directive. As a result, the GloBE Rules have been implemented in (most) EU Member States. Meanwhile, a number of jurisdictions outside of the EU have not implemented the GloBE Rules yet. These jurisdictions include major economic forces such as the US, India, and China.

In June 2025, the G7 published a statement endorsing a Side-by-Side system that is aimed at exempting U.S.-parented multinational groups from both the Under Taxed Profits Rule (UTPR) and Income Inclusion Rule (IIR). No official guidance has been released by the OECD in this respect yet. Hence, the current GloBE Rules remain applicable to in-scope groups until further guidance is published by the OECD.

In the meantime, the EU seems to take the position that the implementation of the OECD's Side-by-Side system can be made via Article 32 of the Pillar Two Directive, on which basis no reopening and/or amendment of the Directive would be required. The question is how robust this will be. Furthermore, a preliminary reference procedure is now pending before the CJEU, concerning the validity of the UTPR in light of fundamental rights and principles of EU law (see Section 2.2. below).

At the time of preparing this publication, no official news has been published in view of extending the UTPR Safe Harbour to protect undertaxed profits of certain UPEs against the UTPR. Without extension hereof, such undertaxed profits at UPE level could be subject to the UTPR as of FY 2026.

With the Transitional CbCR Safe Harbour generally also expiring at the end of FY 2026 and the first GloBE Information Returns and Top-up Tax returns having to be filed in 2026, the year to come is expected to be a pivoting one from a Pillar Two perspective.

Takeaways and tips

• Monitor international developments regarding the negotiations on the 'Side-by-Side' system and guidance from accounting boards.
• Timely prepare for the first GloBE Information Return filings.
• Monitor EU developments regarding the Pillar Two Directive in view of pending litigation about the validity of the UTPR under EU law.

The 2025 Update to the OECD Model

An important development expected to shape the international tax landscape in 2026 is the 2025 Update to the OECD Model Tax Convention on Income and Capital (OECD Model) reflecting the latest developments in international taxation and offering enhanced guidance for the interpretation and application of tax treaties (the 2025 Update).

Developed and negotiated during the past few years by the OECD's Working Party No.1, the 2025 Update was approved by the OECD Council on 18 November 2025 and will be incorporated into the forthcoming edition of the OECD Model to be published in 2026.

The key changes introduced by the 2025 Update include, among others, the following:

• MAP (Changes to Article 25 and its Commentary): In this regard, the 2025 Update confirms the role of competent authorities in determining whether a matter falls within the scope of a tax treaty for purposes of dispute resolution under the General Agreement on Trade in Services. Furthermore, it introduces changes related to Amount B, aimed at enhancing tax certainty and eliminating double taxation, by preserving the optionality of dispute resolution mechanisms for jurisdictions that do not adopt such a measure.
• PE (Changes to the Commentary on Article 5 regarding home office PE and the exploration and exploitation of extractible natural resources): Regarding the PE concept, the 2025 Update clarifies the circumstances in which an individual's home or other relevant places could constitute a "fixed place of business" of the enterprise for which the individual works. Moreover, the 2025 Update adds an optional provision addressing activities related to the exploration and exploitation of extractible natural resources, introducing a lower PE threshold for countries to agree on.
• Associated Enterprises (Changes to the Commentary on Article 9): The 2025 Update clarifies the application of Article 9 in relation to domestic interest deductibility rules, including those recommended in the final report on BEPS Action 4. Moreover, it introduces corresponding updates to the Commentaries on Articles 7 and 24 to align with these changes.
• Exchange of Information (Changes to the Commentary on Article 26): Regarding exchange of information (EOI), the 2025 Update provides an express clarification that information obtained through EOI may be used for tax matters involving people 'other than those to whom the information originally relates'. Furthermore, it reflects the agreed interpretative guidance on taxpayer access to exchanged information and the disclosure of non-taxpayer-specific information derived from such exchanges.
• Other changes: The 2025 Update also introduces other changes to ensure consistency across the OECD Model following the updates described above.

Finally, the 2025 Update also includes the changes and additions made to the observations and reservations of OECD Member countries and the positions of non-Member economies.

For a more in depth overview of the 2025 Update, see our dedicated web post on this topic.

Takeaways and tips

• Review all the changes introduced by the 2025 Update, as they may already influence tax authorities' interpretation of existing treaties.
• Understand new guidance on Home Office PE, assess potential PE risks, and update your remote work policies accordingly.

Mutual Agreement Procedures

As global tax rules grow increasingly complex, MAP have become a useful instrument for international tax certainty. MAP provide a formal mechanism for resolving cross-border disputes between jurisdictions, particularly in cases of double taxation or inconsistent application of transfer pricing rules.

For MNEs, MAP offer clarity and consistency in an environment of diverging interpretations of international tax provisions. It no longer functions merely as a reactive dispute resolution tool. MAP are evolving into a strategic instrument for managing tax risk. Proactive engagement, robust documentation, and early identification of bilateral/multilateral exposure will be critical for navigating this landscape.

Looking ahead to 2026, the following aspects should be considered by MNEs. First, regarding MAP caseload and resolution times, recent OECD data shows that MAP inventories remain high and resolution times average 27.4 months, with transfer pricing cases taking even longer. While the BEPS Action 14 minimum standard aims for a 24-month resolution, this remains aspirational for many jurisdictions. With increasingly complex global supply chains, MAP demand is expected to rise further. Second, concerning dispute prevention, we notice that tax authorities and businesses are increasingly turning to proactive tools - such as Advance Pricing Agreements (APAs) - to prevent and reduce future disputes. Thus, in 2026 we expect bilateral and multilateral APAs to gain traction as a preferred strategy of MNEs for achieving upfront certainty and minimising the risk of prolonged MAP processes.

Takeaways and tips

• Explore multilateral options: For disputes involving multiple jurisdictions, consider multilateral MAP or APA opportunities early.
• Invest in prevention: Strengthen documentation and evaluate APAs to reduce future disputes.
• Early engagement: Early and open communication between tax authorities and taxpayers will be essential. Providing timely guidance, standardised compliance requirements and clear documentation expectations helps
  prevent disputes.

Digital Taxation: Pillar One and DSTs

A decade after the launch of the OECD's BEPS initiative, the taxation of MNEs in the digital economy remains one of the most complex and politically charged issues in international tax policy. As we enter 2026, this topic demands continued
attention from MNE, particularly in light of recent developments and the OECD priorities.

The lack of progress toward signing the Multilateral Convention to Implement Amount A of Pillar One (MLC), the OECD's shift in focus towards the Side-by-Side system, and the expiration of the standstill and withdrawal commitments on DSTs in mid-2024 have collectively fuelled the perception that Pillar One is no longer viable, simultaneously accelerating the expansion and proliferation of unilateral DSTs.

While renewed retaliatory threats from the Trump administration have tempered this DST momentum, they have not prevented some European countries from expanding the scope and rates of their existing DSTs (e.g. Italy and France) and/or considering the adoption of a new DST (e.g. Germany). Notably, France's Constitutional Court ruling in 2025 upholding the legality of the French DST has further emboldened these unilateral actions.

Beyond the threats noted above, the US is actively working to prevent the spread of national DSTs by incorporating a specific commitment to 'refrain from imposing discriminatory digital services taxes' in its recent trade agreements with several Asian and Latin American countries. Although primarily viewed as a potential response to a hypothetical frustration of the Side-by-Side system, a revival of the proposed Section 899 by the US could also be triggered by countries' attempts to introduce new DSTs.
At the EU level, the trade tensions with the US and the search for new EU revenue have reignited discussions around the need for a European DST. Despite the European Commission's stated preference for a multilateral solution and its reluctance to table a new EU proposal at this stage, the 2018 proposal for a European DST has not been withdrawn from the Commission's 2026 work programme. While a reactivation of the 2018 proposal is not expected in 2026, the policy debate on this topic will continue to gain traction in both national and EU fora, especially when Pillar One negotiations remain on hold.

Looking ahead, while international talks on Pillar One may resume once key issues around the Side-by-Side system are resolved, MNEs should prepare for a continued landscape of fragmented unilateral measures, with certain jurisdictions - particularly in Europe - exploring the expansion of their existing digital tax measures despite geopolitical tensions and trade risks.

Takeaways and tips

• Prepare for a continued patchwork of unilateral DSTs: Since expansions of existing DST regimes remain possible, companies providing digital services should actively monitor these developments, assess potential impacts, and update compliance processes accordingly.
• Monitor EU developments: Despite the EU Commission's commitment to a global solution, informal debates on an EU DST continue within various policy circles. Thus, companies should closely follow and proactively engage in these discussions to anticipate potential regulatory changes.

The EU-US trade deal: Exchanging uncertainty for stability

Following various tariff increases and negotiations, on 21 August 2025, the US and the EU issued a Joint Statement establishing a framework for trade and investments following a political agreement reached by EU Commission's President von der Leyen and US President Trump on 27 July 2025 (Joint Statement). Below is a concise overview of the key commitments outlined in the Joint Statement:

The US will apply a tariff ceiling of 15% for most EU exports. Either the Most Favored Nation (MFN) tariff or a 15% rate - whichever is higher - will apply to imports of products originating in the EU from most sectors, including cars, semiconductors, pharmaceuticals, and lumber. Certain EU products, such as unavailable natural resources, aircrafts and aircraft parts, will only be subject to the MFN rate. The EU will eliminate tariffs on all industrial products originating in the US. In addition, the EU will provide preferential market access for a wide range of US seafood and non-sensitive agricultural products, with tariff reductions applied through tariff quotas. Sensitive agricultural products from the US such as beef, poultry, rice, and ethanol are excluded from the trade deal.

The Joint Statement indicates that the US and EU will negotiate rules of origin to ensure that the benefits of the political agreement accrue primarily to the US and the EU. For now, non-preferential rules of origin apply.

Aside from tariff measures, the EU has committed to easing several non-tariff barriers affecting US-EU trade. This includes streamlining sanitary certificate requirements for pork and dairy products and offering greater flexibility in the implementation of Carbon Border Adjustment Mechanism (CBAM) for US small and medium enterprises (SMEs). The EU also states that it will address concerns over the EU Deforestation Regulation. Furthermore, the EU aims to further minimise trade restrictions under the Corporate Sustainability Due Diligence Directive (CSDDD) and Corporate Sustainability Reporting Directive (CSRD) by reducing administrative burdens and reconsidering certain liability provisions related to due diligence failures and climate transition obligations.

Finally, the EU committed to procure $750 billion worth of US energy products, such as LNG, oil and nuclear energy products through 2028, and $40 billion in US AI chips, while also advancing transatlantic investment, thus expecting EU companies to invest $600 billion across strategic US sectors.

Takeaways and tips

• Greater clarity expected in 2026: Although the trade deal between the US and the EU is promising, it should be noted that it only outlines political commitments. Moreover, the proposals of the European Commission implementing part of the trade deal are still pending. It is expected that in 2026, the introduction of legal instruments and further negotiations between the US and the EU will provide additional clarity.
• Prepare for compliance and assess the impact of tariffs' costs: In the meantime, US and EU traders can prepare by verifying whether the tariff classification, origin, and customs value of imported and exported products are correct and/or can be optimised. They should also determine which party in a transaction bears the cost of tariff measures for imports into the EU and/or US.

The European landscape

Introduction

The European tax landscape is in full development, with 2025 marking one of the most dynamic years in what concerns direct taxation. We have closely monitored these EU law developments and are delighted to share our view on this with you, including an outlook and next steps.

A defining trend in this area is the EU's ambition to take a leading role on global tax reform, as seen in the adoption of the Pillar Two Directive. In 2025, this frontrunner role has led to tensions and a closer scrutiny on EU tax measures, from both Member States and international partners. Legal challenges - such as the preliminary questions referred to the CJEU on the UTPR under the Pillar Two Directive and the procedures in relation to solidarity contributions from oil and gas companies - are testing the limits of EU legislative power.

In 2025, we have seen a recalibration of existing initiatives that would harmonise national tax laws, while also actively utilising soft law to provide more guidance for Member States and taxpayers. While several complex or controversial legislative proposals have been withdrawn (e.g., Unshell, DEBRA and TP), those that are still on the Commission's agenda mostly aim to the benefit taxpayers by increasing simplification and competitiveness. These proposals include the EU Blue Carpet Initiative, the Clean Industrial Deal and the "Omnibus on taxation" package, which is expected to streamline existing directives such as the ATAD and the Directive on Administrative Cooperation (DAC). Other pending EU initiatives - such as the proposal for an annual lump sum contribution for large enterprises - signal the Commission's continued intention of exercising fiscal influence within the Single Market. The direction of EU tax law is increasingly shaped by both national courts and the CJEU.

Moreover, the same tax questions are often relevant across all Member States, making awareness essential. As we look ahead to 2026, staying informed and adaptable to these ongoing trends will be crucial for navigating this evolving tax environment.

Implementation of Pillar Two under pressure in the EU

The year 2025 has also been an important year for the implementation of Pillar Two by EU Member States. The EU initially acted as the frontrunner in the implementation of the work carried out by the OECD and Inclusive Framework (IF) in this regard. With increased international pressure on Pillar Two because of the US position and the G7's agreement on a 'Side-by-Side' system, the EU implementation of this measure has also been scrutinised.

On 17 July 2025, the Belgian Constitutional Court referred preliminary questions to the CJEU on the validity of the UTPR in the Pillar Two Directive. A decision can be expected by the end of 2026 at the earliest. This fundamental case will be the first moment for the CJEU to rule on the validity of the EU's efforts on Pillar Two.

Moreover, the G7 reached an agreement regarding the potential application of the Pillar Two rules on US-based multinationals. While further details have not materialised yet, the agreement would likely entail that US-based multinationals (and certain other multinationals if located in a jurisdiction with an eligible system) would be excluded from the scope of Pillar Two (the Side-by-Side System). The QDMTT remains to apply, also to such groups. The G7 agreement raises fundamental questions on its implementation in the EU legal order, particularly whether Article 32 of the Pillar Two Directive can serve as an appropriate legal basis to implement such an agreement or if additional legislation is required at an EU level. The Side-by-Side System (once adopted) illustrates fundamental and practical issues with the Pillar Two Directive. An important issue, expected to further materialise in 2026, is whether the work carried out at by the OECD and IF (including commentaries and so-called administrative guidance) can be used for a dynamic interpretation of the Pillar Two Directive.

We expect discussions on these fundamental and practical challenges to intensify in the coming years, with an increased focus on general principles of EU law and fundamental rights.

Takeaways and tips

• EU's implementation of Pillar Two is under pressure: The preliminary questions on the validity of the UTPR in the Pillar Two Directive and the (potential) implementation of a Side-by-Side System put the EU's implementation of Pillar Two under further pressure.
• Developments in this area should be closely monitored: The CJEU's findings on the UTPR under the Pillar Two Directive are likely to set a key precedent for challenging adverse tax provisions included in secondary EU legislation.

CJEU to rule on validity of solidarity contribution levied from oil and gas sector

In October 2022, the Council adopted Regulation 2022/1854 countering high energy prices (Regulation). The Regulation mandates Member States to levy a solidarity contribution from oil and gas companies and a mandatory cap on market revenues. There are several cases questioning the validity of this Regulation pending before the General Court of the EU and the CJEU.

EU action in the field of direct taxation traditionally requires unanimity from all Member States. The regulation closely links to taxation of Member States, but is adopted on a specific legal basis for emergency measures. This legal basis does not
require unanimity, but instead only requires the Council to adopt a decision with qualified majority.

The cases are quite fundamental for the constitutionality of EU tax harmonisation. Questions have been referred to the CJEU whether, despite the contribution not being labelled as a tax, the EU legislator is bound by the unanimity requirement for the fiscal measures included in the Regulation. The decision of the CJEU on these questions could shape the ways in which the EU can act in the field of direct taxation.

Takeaways and tips

• The CJEU judgment on the solidarity contribution from oil and gas companies may shape the ways in which the EU can act in the field of direct taxation: These procedures could define how the EU can legislate on direct taxation and whether 'unanimity' from all Member States continues to be the only option available for the Council for such purposes.

Advocate General questions validity of the ATAD

In a recent opinion, Advocate General Kokott questioned whether the EU rightfully adopted the ATAD and the anti-hybrid mismatch rule in the Parent Subsidiary Directive (European Commission v Belgium, Case C-524/23). These doubts affect the constitutional basis of EU tax law. If the CJEU ultimately (partly) agrees with the Advocate General, the impact on both existing and upcoming tax directives would be significant.

As background, each act of the EU must have a valid legal basis under the TFEU. EU tax directives can only be adopted unanimously by all Member States and must "directly affect the establishment or functioning of the internal market". The Advocate General questions whether the ATAD positively affects the internal market, notably because national anti-abuse measures restrict the free movement within the EU.

The absence of a correct legal basis would lead to the annulment of the ATAD. This would be especially relevant for the national implementation of this directive, such as the provisions on earning stripping and various anti-hybrid mismatch rules. While the matter will likely not be considered by the CJEU in the pending case (for procedural reasons), it seems to be only a matter of time until a question on this matter is referred to the CJEU by a national court.

Takeaways and tips

• Doubts raised on ATAD's legal basis will increase scrutiny: Recent doubts about sufficient legal basis recently raised by Advocate General Kokott cast further doubt on the validity of the ATAD and will likely increase legal scrutiny against the earning stripping and anti-hybrid mismatch rules.

European Commission shifts focus

The European Commission is shifting its EU tax policy strategy, moving away from proposing hard legislation to combat tax avoidance and evasion or implementing OECD-designed measures, and placing greater efforts on both developing its own EU-centered initiatives mainly aimed at promoting simplification and EU competitiveness. Central to this shift are the forthcoming "Omnibus on taxation" package, the withdrawal of several pending legislative proposals deemed less aligned with the new EU priorities and the preservation of other proposals amid ongoing international negotiations. These three aspects are further discussed in the sections below.

Simplification and competitiveness

The European Commission has indicated that a proposal for simplifications in various existing EU tax directives is expected to be presented in Q2 2026 under the so-called Omnibus on taxation package (OTP). The OTP may require Member States to amend their implementation of among others the ATAD and the DAC and could therefore have a significant effect on taxpayers.

The European Commission is considering technical adjustments to mitigate the procyclical effects of ATAD's earnings stripping rule, possibly by accounting for inflation, loss-making years, revising the treatment of third-party loans, and clarifying the exemption for public infrastructure and social housing. For the controlled foreign company rule of the ATAD, the aim is rationalisation and simplification through a single harmonised model instead of the current dual system, likely with exemptions for SMEs. The reform focuses on ensuring consistency and reducing administrative burdens rather than expanding the material scope of the existing rules.

The second part of the OTP will likely recast the DAC. The European Commission aims to streamline overlapping provisions and improve coherence across the existing framework, from DAC1 to DAC9. Particular attention will be given to the hallmarks in the Mandatory Disclosure Rules (DAC6), which drew strong criticism during public consultation. Several hallmarks may be revised. The hallmarks from the proposal to address the misuse
of shell entities (the Unshell Proposal) may be incorporated directly into the DAC. Further specific amendments to other versions of the DAC (e.g. rules on tax reporting by digital platforms under DAC7) are also expected. The expected recast of the DAC will be based on the latest evaluation of such a directive made by the European Commission and published on 19 November 2025 (see our dedicated web post on this development).

The OTP also reflects the European Commission's intention to improve EU competitiveness by ensuring simpler regulation and smoother implementation of EU rules. These priorities are also reflected in several (upcoming) initiatives in the field of direct taxation, including the Commission recommendation on the tax treatment of sustainable investments (Clean Industrial Deal) and the expected recommendation on the tax treatment of Employee Stock Options (Blue Carpet Initiative)

Takeaways and tips

• EU simplification package may reshape the ATAD and the DAC: The simplification package being prepared by the European Commission could significantly impact existing directives like ATAD and DAC and reshape compliance rules and national anti-abuse rules (notably, earnings stripping).

Withdrawals of other proposals: Unshell, DEBRA and TP Directives

Because of the European Commission's new priorities, the latter has recently announced that several pending tax proposals that allegedly do not seem to contribute to the goal of enhancing EU competitiveness will formally be withdrawn. These include the proposals for an Unshell Directive, the Debt-Equity Bias Reduction Allowance (DEBRA Directive) and the Transfer Pricing Directive. Particularly, the proposal for an Unshell Directive (also known as ATAD3) was considered to be the most relevant for practice. As mentioned above, parts of the Unshell Directive might be included in the DAC recast.

Pending proposals

Several other EU direct tax proposals will remain pending, notably the proposal for acommon consolidated corporate tax base (BEFIT), the proposal for a DST and the proposal for corporate taxation based on a significant digital presence. It seems that the Commission intends to continue the work on BEFIT, despite the initial objections by Member States in view of their sovereignty. The proposals in relation to digital taxation measures will likely remain pending due to the absence of an agreement on Pillar One. These proposals may be revived once there is more clarity in that respect.

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