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OECD/International - Earth to OECD: You Must Be Joking – The Subject to Tax Rule of Pillar Two

In this article from the Bulletin for International Taxation, Brian J. Arnold examines the implications of the Subject to Tax Rule (STTR) of the OECD’s Pillar Two for developing countries. He argues that the STTR is unreasonably complex, and will not be advantageous for developing countries. Accordingly, developing countries should be very cautious in adopting the STTR.

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Our renowned articles provide readers with information on important international tax developments and offer the most extensive coverage in the tax community in terms of countries, topics and authors.

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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 

United Nations/International - Driving a Hard Bargain: A Sneak Preview of the UN Framework Convention Negotiations


Last December, the UN boldly claimed a significant role in setting international tax policy when it voted overwhelmingly to develop a Framework Convention on International Tax Cooperation. Work has now begun on realizing the UN’s vision. In this Talking Points, Bob Michel highlights the procedural and substantive issues under consideration, and reviews the stated positions of a broad cross-section of countries in the developed and developing world as the negotiations ramp up.  

Bob Michel is an international tax expert and author

Bob Michel is an international tax expert and author. He is active as a consultant for various organizations, including the Tax Justice Network, the International Association of Tax Judges, GIZ and IBFD. The opinions expressed in this article are the author’s own. He can be contacted at



Bob Michel

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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