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Effective Tax Rate Criteria and Source Taxation under the OECD’s Pillar Two Proposals

In this article from the Bulletin for International Taxation Journal, Luis Eduardo Schoueri and Bruno Cesar Fettermann Nogueira dos Santos aim to analyse how the effective tax rate criteria of the OECD’s Inclusive Framework Pillar Two proposal affects source taxation, particularly with regard to its effects on developing countries as source countries.

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Talking Points

Talking Points is a brand-new service that provide IBFD users with market-leading commentary and analysis on the latest and hottest developments in international taxation. 

Talking Points showcase thought leadership from around the world on key developments, news items and other important international tax topics. IBFD readers will benefit from valuable insights, reasoning, opinions and viewpoints putting tax developments in perspective from some of the most prominent leaders in international taxation.

This series of papers aims to enlighten the international tax community on matters of significant interest. Although all relevant aspects were critically analysed, your feedback is always welcome.

Monthly Talking Points articles are available to subscribers with Tax News Service (TNS) access. 

To view one of IBFD's free Talking Points papers on the IBFD Tax Research Platform (TRP), click on the links below.

Latest Free Talking Points 

Ireland/European Union - Faraway Hills May Not Be Greener; Can Ireland Maintain Its Competitive Advantage With a 15% Minimum Tax?

With its attractive 12.5% corporate tax rate, Ireland would seem to be most heavily impacted by the European Union’s decision to adopt the Pillar Two 15% global minimum tax. With implementation looming in 2024, questions have arisen about whether Ireland will be able to maintain its competitive advantage, even with the higher tax rate. In this Talking Points, Anna Crowley examines the steps the Irish government has taken to ward off any ill effects of the rate hike, as it seeks to maintain its position as an attractive location for foreign direct investment.

Anna Crowley, Senior Associate and Chartered Tax Adviser at Matheson.

Anna Crowley advises Irish and multinational clients on corporate and international tax and transfer pricing. Anna also advises clients in relation to tax-effective structures for inbound and outbound investment and cross-border reorganisations. She assists leading multinational corporations with tax authority audits, competent authority matters and multi-jurisdictional tax controversies. She can be reached at



Anna Crowley

Free Talking Points currently available

OECD/International - The Unhelpful Myth of Tax Certainty

One key component of the OECD’s Pillar One proposal to reallocate taxing rights from producer to consumer nations is the promise that businesses and governments affected by this change will be able to achieve something called “tax certainty”. But what exactly is “tax certainty”? In this Talking Points piece, Peter A. Barnes looks at whether it is possible to achieve certainty in any aspect of business, let alone in the complex world of international taxation, and suggests a more productive way forward.

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Ukraine - The Impact of War on Tax Policy – Lessons from Ukraine

Russia’s military invasion of Ukraine has demanded urgent changes to Ukrainian tax policy, resulting in the adoption of over 20 tax-related laws since the war began in February 2022. The parliament has prioritized measures that ease the tax burden on businesses, whose trade has faced unprecedented challenges. Tetyana Zhuravska’s article discusses some of the lessons learned, points out the crucial wartime tax policy developments and comments on further proposals.

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European Union - Will the European Union Fall in Love with DEBRA?

The European Commission has proposed a new directive to more closely equalize the income tax treatment between equity and debt financing for corporations doing business in EU Member States. Carla Valério examines the details of the proposal – with the clever acronym DEBRA – and looks at what it could mean for European corporations and capital markets, if adopted.

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How Will the World Finally COP to the Realities of Pricing Carbon?

Carbon pricing was high on the agenda at last year’s United Nations Climate Change Conference, known as COP26. Rafael Barbosa de Sousa explains what tax professionals need to know about carbon pricing and carbon taxation, and cautions policymakers to carefully consider all the consequences – intended and unintended – before enacting carbon taxes.

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Crossing the Digital Services Tax Divide – But Is It Worth the Journey? by George L. Salis

Despite compelling legal and constitutional barriers to digital services taxes (DSTs) in the United States, more states are moving forward with EU-style DST taxing models in the post-COVID economy. How did we get here, and what do tax professionals need to know about this growing trend?

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IBFD Tax Takes: News & Views

IBFD’s video series Tax Takes: News & Views provides our worldwide tax community with the latest key news and insights. First up will be the week’s top news, selected from IBFD’s market-leading Tax News Service, followed by an interview on a current hot or emerging topic with a leading tax expert.




Episode: Global Tax Reform: Is OECD the Only Game in Town?


The views: Is the OECD’s BEPS Project still on course, or has it veered away from its original intent to reduce profit shifting? Michael Devereux (Director, Oxford University Centre for Business Taxation) and Stuart Gibson (Chief Editor, Global News and US, IBFD) discuss alternative approaches to tackle the BEPS Project’s current challenges.

The news: This week’s episode kicks off with news on:

  • Colombian court blocks COVID-19 relief while other countries step up efforts 
  • Canada targets online platforms while Estonia shelves its plans
  • Gibraltar starts losing EU tax benefits 

Previous episodes of IBFD Tax Takes: News & Views

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