What the OECD Released on 8 September 2026
On 8 September 2026 the OECD published Tax Policy Reforms 2026, the eleventh edition of its annual comparative review of tax policy. The report catalogues the tax changes introduced or announced during 2025 across the 92 member jurisdictions of the OECD/G20 Inclusive Framework on BEPS, including every OECD country. Where the OECD's Corporate Tax Statistics database (released in July) counts the money, Tax Policy Reforms tracks the choices — which levers governments pulled, in which direction, and why.
The accompanying press release framed the mood precisely: governments are reforming tax systems to boost growth, but revenue pressures continue to mount. Rising public debt, higher debt-servicing costs, ageing populations and — increasingly — defence spending are all pushing finance ministries to find revenue. What the 2026 report shows is how they are finding it, and the answer has shifted away from the headline corporate rate toward a patchwork of targeted, sector-specific and cross-border measures that matter directly to multinationals.
The Big Picture: Revenue Pressure Meets Growth Goals
The report's central tension is that governments want to support growth — through targeted investment incentives and, in several countries, personal-tax relief for lower earners — while simultaneously raising revenue to stabilise strained public finances. In 2025 that balancing act produced a distinctive pattern: broad corporate rates left largely alone, but a proliferation of narrow, revenue-focused measures layered on top, together with more progressive personal and capital taxation.
For internationally active businesses, three of those threads matter most, and this analysis takes each in turn: the shift from headline corporate rates to targeted levies on banks and excess profits; the continued global expansion of digital and platform taxation, including VAT on non-resident suppliers and new platform withholding; and a clear move toward heavier taxation of capital income — dividends, gains and wealth — in major economies. Each carries cross-border consequences that a purely domestic reading of the report would miss.
Corporate Rates Hold, But Targeted Levies Multiply
The most striking structural finding is continuity: the average combined corporate income tax rate across the Inclusive Framework was broadly stable for a third consecutive year, and — for the second year running — more jurisdictions raised their corporate rate than cut it. The two-decade "race to the bottom" in headline corporate rates has, on the OECD's evidence, halted and shows early signs of reversing — a shift the OECD links to the arrival of the 15% global minimum tax, which removes much of the incentive to keep undercutting.
But stability in the headline rate masks a surge in targeted, sector-specific corporate taxes, often aimed at raising revenue for the general budget. A growing number of countries — including in 2025 — increased taxes on banks and other financial institutions, frequently focused on the excess profits generated during the high-interest-rate period. Two examples the report highlights:
| Jurisdiction | 2025 measure | Detail |
|---|---|---|
| Israel | One-time bank levy (2026–2027) | Large banks to pay NIS 3bn in 2026 and NIS 250m in 2027 on exceptional interest-rate-driven profits |
| Belgium | Higher bank & insurance taxes | Increased existing bank tax rates; insurance premium tax raised from 9.25% to 9.6% |
| Inclusive Framework (avg.) | Combined corporate rate | Broadly flat — 3rd consecutive year |
| Rate-change balance | Increases vs. cuts | More jurisdictions raised than cut — 2nd year running |
Digital & Platform Taxation Keeps Expanding
The second major theme is that the taxation of the digital economy continued to broaden in 2025 — on both the VAT and the direct-tax side. On VAT/GST, the report notes that reforms linked to digitalisation were among the most significant consumption-tax changes of the year, with more jurisdictions extending collection obligations to non-resident suppliers and online platforms. This "platform economy" VAT expansion directly increases the compliance footprint of any business selling cross-border into those markets, regardless of physical presence.
On direct and withholding taxes, the picture is more mixed but no less active. Mexico introduced a new withholding scheme for entities transacting through intermediation platforms; Türkiye moved to reduce its digital services tax; and Canada completed the repeal of its Digital Services Tax, refunding amounts collected — a retreat driven by trade pressure from the United States (see the Canada Revenue Agency notice). The direction of travel differs by country, but digital taxation remains one of the most fluid areas of international tax:
| Country | Digital-economy measure (2025) | Rate / effect |
|---|---|---|
| Mexico | Withholding on platform-intermediated transactions | 2.5% with tax-ID (RFC); 20% without |
| Türkiye | Digital services tax cut | 7.5% → 5% (2026), then 2.5% (2027) |
| Canada | Digital services tax repealed | 3% DST rescinded; amounts refunded |
| Multiple | VAT on non-resident suppliers & platforms | Collection obligations extended |
Personal & Capital Income Taxes Turn More Progressive
Where corporate headline rates held, personal taxation did more of the heavy lifting. The report finds 2025's personal income tax (PIT) reforms were, on balance, revenue-raising and progressive — higher top marginal rates in several countries, paired in some with relief lower down the scale. Alongside that, governments moved toward heavier taxation of capital income: dividends, capital gains and the returns on wealth.
Two of the largest European economies illustrate the trend. In the United Kingdom, ordinary and upper dividend tax rates rise to 10.75% and 35.75% from April 2026. The Netherlands, meanwhile, is overhauling its "Box 3" regime: from 2028 a revised system based on actual returns replaces the old deemed-return model, functioning largely as an accrual-based capital-growth tax, with a realisation-based capital gains tax for asset classes such as real estate and shares in start-up companies.
| Country | Capital-income reform | Change |
|---|---|---|
| United Kingdom | Dividend tax rates (from April 2026) | Ordinary → 10.75%; upper → 35.75% |
| Netherlands | "Box 3" capital-income regime (from 2028) | Move to actual-return basis; accrual capital-growth tax + realisation CGT on real estate & start-up shares |
| OECD (trend) | Personal income tax | More progressive — higher top rates |
What It Means for Cross-Border & Withholding Tax
Read as a whole, Tax Policy Reforms 2026 tells cross-border tax teams that the action has moved off the corporate rate card and onto everything around it. Platform-withholding regimes like Mexico's create new withholding obligations where none existed; expanding VAT-on-non-resident rules pull foreign sellers into local registration and collection; and rising residence-country taxes on dividends and gains raise the payoff from optimising source-country withholding through treaties.
The one constant is that statutory withholding tax on cross-border dividends, interest and royalties remains a first-order cost — the OECD's own datasets put average statutory (non-treaty) WHT in the low-to-mid teens, and a treaty between the payer's and recipient's countries is usually what brings that down to single digits. Every new levy layered on elsewhere makes the WHT-and-treaty layer worth getting right. For headline rates by country see our Withholding Tax Rates by Country guide, and for accessing reduced rates our How to Claim Tax Treaty Benefits guide.
What Affected Taxpayers Should Do
The report is a policy map, not a compliance checklist — but the pattern it documents translates into concrete actions for internationally active businesses and their advisers.
- Screen for sector levies. If your group operates in banking, insurance or energy, check for new or increased sector-specific charges — like Israel's bank levy or Belgium's higher bank and insurance taxes — that sit outside the standard corporate tax base and can be missed in rate-based forecasts.
- Map platform-VAT and platform-withholding exposure. Selling cross-border into a market that has extended VAT to non-resident suppliers, or transacting through an intermediation platform in a country like Mexico, can create registration, collection or withholding duties with no physical presence. Identify these before, not after, the first transaction.
- Re-run withholding and treaty positions. With residence-country taxes on dividends and gains rising (UK, Netherlands), the value of every treaty reduction and foreign tax credit on the source-country side goes up. Reconfirm beneficial-ownership and documentation on each material flow.
- Watch the direction, not just the rate. Corporate headline rates are stable, but "stable" now means flat-to-rising. Planning built on an assumption that rates keep drifting downward is planning against the trend the OECD now documents.
For related reading, see our analysis of the OECD's first global-minimum-tax revenue data and our Digital Services Tax landscape 2026 guide.
Frequently Asked Questions
What is the OECD Tax Policy Reforms 2026 report?
It is the eleventh edition of the OECD's annual comparative review of tax policy, published on 8 September 2026. It documents the tax reforms introduced or announced during 2025 across the 92 member jurisdictions of the OECD/G20 Inclusive Framework on BEPS, covering corporate, personal, consumption, property and environmental taxes.
Did corporate tax rates go up in 2025?
On average, no — the combined corporate income tax rate was broadly stable for a third consecutive year. But the long downward trend has stopped: for the second year running, more jurisdictions raised their corporate rate than cut it, and many governments added targeted, sector-specific levies (notably on banks and financial institutions) rather than moving the headline rate.
Which countries introduced new bank or windfall taxes?
Among the examples the report highlights, Israel agreed a one-time levy under which large banks pay NIS 3 billion in 2026 and NIS 250 million in 2027 on exceptional profits, and Belgium increased existing bank taxes and raised its insurance premium tax from 9.25% to 9.6%. The broader trend is a growing use of sector-specific taxes on financial institutions' excess profits.
What changed in digital and platform taxation?
More jurisdictions extended VAT collection obligations to non-resident suppliers and online platforms. On direct taxes, Mexico introduced platform withholding of 2.5% (with a tax-ID) or 20% (without), Türkiye cut its digital services tax from 7.5% to 5% for 2026 and 2.5% for 2027, and Canada repealed its Digital Services Tax and refunded amounts collected.
How does this affect withholding tax on cross-border payments?
Two ways. New platform-withholding regimes create fresh source-country withholding obligations, and rising residence-country taxes on dividends and capital gains — for example the UK's higher dividend rates from April 2026 — increase the value of claiming every available treaty reduction and foreign tax credit on the withholding side. Statutory WHT on dividends, interest and royalties remains a first-order cost that treaties typically reduce substantially.
For a foundational explanation of how cross-border withholding and treaty relief work, see our How to Claim Tax Treaty Benefits guide, or jump straight to the WHT Calculator.