President escalates tax dispute, warning of import tariffs against countries imposing Digital Services Taxes on US tech companies
US President Donald Trump has escalated on 25 June 2026 his opposition to European Digital Services Taxes (DSTs), threatening to impose 100% tariffs on all imports from countries that introduce or expand taxes targeting US digital companies.
In a social media statement on 26 June 2026, Mr Trump warned that any country implementing a DST would face immediate retaliatory tariffs on exports to the United States. The proposed measures would apply regardless of any existing or future trade agreements.
The threat marks a significant escalation in the long-running dispute over how governments tax the revenues of large multinational digital businesses such as Google, Meta, Amazon and Apple.
OECD Pillar 1 tax reform compromise was intended to reach a compromise to do away with DST’s, but has stalled since the US pulled out of talks at the start of the Trump Presidency in 2025.
Europe revisits Digital Services Taxes
Trump’s latest warning follows renewed political discussion across Europe over raising additional revenues from large digital platforms.
The European Parliament has recently expressed support for an EU-wide Digital Services Tax as part of wider discussions on new EU own resources. However, any EU-wide DST would require unanimous approval from all 27 Member States, making adoption politically difficult.
Separately, several European countries continue to operate national DST regimes, while others have explored introducing new measures as governments search for additional tax revenues.
Legal basis shifts to Section 301
The White House indicated that any retaliation would rely on Section 301 of the US Trade Act of 1974, allowing the United States to impose trade measures where foreign taxes or practices are considered discriminatory or restrict US commerce.
The move is notable because the Trump administration has increasingly relied on Section 301 authorities following recent US court challenges to tariffs imposed under emergency economic powers.
EU promises swift response
The European Commission responded by defending Digital Services Taxes as legitimate domestic tax measures rather than discriminatory trade barriers.
An EU spokesperson warned that unilateral US tariffs targeting lawful tax policy would be unjustified and stated that the EU would respond “swiftly and decisively” to protect its regulatory autonomy.
The exchange raises the prospect of another transatlantic trade dispute at a time when both sides are already negotiating wider tariff arrangements.
May 2025: US House of Representatives bill passed with threats of fines on countries imposed unfair taxes, including Digital Services Taxes
In February 2025, President Trump memo orders review of remedies against global digital taxes targeting US tech. Canada, France, Italy, Spain, Turkey & UK DST’s singled out
On 22 May, the US house passed a bill to impose fines on countries imposing unfair taxes – including extraterritorial, discriminatory other similar taxes. This covers the Digital Services Taxes, imposed by many European and other countries to tax non-resident providers of digital services to their consumers.
On 21 February 2025, US President Trump signed an order to investigate potential tariff retaliations against countries which have implemented . The memo targets 6 countries’ DST’s: France; the UK; Italy; Canada, Spain, and Turkey. A public consultation starts 6 March, and April 2025 to initial outcome will be published as part of the America First Trade Policy Memorandum.
UK, Italy, Uganda, Kenya and others start DST reviews to placate US
The review has already sparked a likely UK DST withdrawal and Indian Equalisation Levy for fear of tariffs. Italy and US in April signed a declaration to reform the Italian DST. Kenya and Uganda have also indicated they will replace their DST’s with Withholding Taxes which are provided for within double taxation treaties.
See our global DST tracker which follows around 30 DST’s which are revenue taxes on social media, search engine or online marketplace services. They effectively act as an import tariff on digital services, and the US is upset that their high annual thresholds mean they largely discriminate against US digital giants like Google, Meta, Apple and Amazon. Countries implementing DST’s argue the reflect the shortcomings of the 100+ year-old existing global tax settlement which is unable to fairly tax modern digital offerings.
US tariff retaliations as it pulls out of OECD negotiations?
On 20 January 2025, President Trump withdrew the US from the global digital tax reform negotiations – OECD Pillar 1 reform – which sort to settle global taxing rights on cross-border digital services. This move to review DST’s follows potential retaliative tariffs against VAT announced by President Trump last week.
The review seems to go beyond just DST’s to evaluate any charge on US-produced content. This could include content levies like the French music streaming levy .
The 2016-20 first Trump administration investigated DST’s, concluded that they constituted violations of trade agreements with the United States. The Trump and following Biden administrations both imposed retaliatory tariffs in response, but suspended them pending the pillar 1 negotiations.
President Trump launches DST review – Feb 2025
On 21 February 2025, President Trump signed a Presidential Memorandum directing the United States Trade Representative (USTR) to review and potentially renew investigations into DSTs imposed by key US trading partners. The memorandum specifically targets France, the UK, Italy, Spain, Austria, Turkiye, and Canada. It aims to identify policies that discriminate against US companies, burden US digital commerce, and undermine their global competitiveness.
USTR DST investigation
- Review and Renewal of DST Investigations:
- The USTR will consider renewing DST investigations under Section 301 of the Trade Act of 1974, which were initiated during Trump’s first term.
- These taxes were previously found to violate trade agreements, leading to retaliatory tariffs, which were later suspended pending negotiations.
- Withdrawal from OECD Tax Reform Negotiations:
- On 20 January 2025, President Trump withdrew the US from the OECD’s global digital tax reform talks.
- Identifying Discriminatory Policies:
- The USTR, in collaboration with the Treasury and Commerce Departments, will examine foreign tax policies that:
- Discriminate against US companies.
- Inhibit US businesses’ growth or intended operations.
- Jeopardize US intellectual property.
- Undermine US companies’ global competitiveness.
- The USTR, in collaboration with the Treasury and Commerce Departments, will examine foreign tax policies that:
Additional Considerations:
- Canada’s DST: The USTR will assess whether to initiate a dispute resolution panel under the United States-Mexico-Canada Agreement (USMCA) over Canada’s DST.
- EU and UK Policies: The USTR will investigate whether EU or UK regulations pressure US companies to modify content moderation, affecting freedom of speech and political engagement.
- Potential Tax Actions: The USTR and Treasury will evaluate whether any foreign tax policy violates US tax treaties or qualifies for retaliatory action under the Internal Revenue Code.
- Securing a Moratorium on Digital Tariffs: The memorandum calls for efforts to establish a permanent ban on customs duties for electronic transmissions, following the WTO’s temporary moratorium extension until 2026.
March 2025 Public consultation
- The USTR has opened a comment period until 11 March 2025, seeking feedback on unfair trade practices.
- The Federal Register Notice encourages submissions, especially concerning major G20 economies and countries with large US trade deficits.
The findings from this review will be published in April 2025 as part of the America First Trade Policy Memorandum.
Levy on untaxed imported digital services
DST’s seek to tax the revenues of mostly US digital giants such as Apple, Amazon, Google and Meta. They apply where in-scope services are provided from abroad, and which therefore are not subject to regular local corporate income tax. They are in effect digital service tariffs, particularly with high eligibility thresholds which exclude all but the largest US-based businesses.
They reflect the archaic basis of the existing global taxing rights which only are triggered when providers have a local presence – employees, facilities etc. Many digital services providers avoid this criteria by supplying from offshore and so avoid income taxes.
The UK is already reported to be reconsidering its £700 million-per-annum DST, and withdrawing it to avoid earlier threats of US retaliation.
Services subject to DST
DST’s are typically around 3%, and levied on revenues derived from the following specific categories of digital services:
- Online Advertising Services: Revenue from placing targeted advertising on a digital interface based on data gathered from users.
- Multisided Digital Interfaces: Revenues from the provision of a digital platform facilitating interaction between users, which may result in the supply of goods or services.
- Transmission of User Data: Revenues derived from selling or transferring data collected about users and generated through their activities on digital platforms.
Europe Digital Services Taxes (DST)
| Country | Status | Rate | Annual sales threshold | Scope | |
| In-country income | Global income | ||||
| EU Digital Levy | Paused | 3% | EU €50m | €750m | Marketplaces; advertising |
| Austria | Jan 2020 | 5% | €25m | €750m | Advertising |
| Belgium | 2027 | 3% | €5m | €750m | Advertising; Intermediation; Data Transmission |
| Czech | Proposed | 5% | CZK 100m | €750m | Advertising; digital services |
| Denmark | Jan 2024 | 2% | Streaming video | ||
| France | Jan 2019 | 3% | €25m | €750m | Digital interface; advertising; user data |
| Germany | TBC | 10% | €25m | €750m | Digital advertising |
| Greece | Jul 2019 | Nil | n/a | Tourist accomodation | |
| Hungary | Jul 2019 | 0% to Dec 2022; then 7.5% | HUF 100m | n/a | Media content; Advertising |
| Italy | Jan 2020 | 3% | Nil | €750m | Advertising; digital interfaces; user data |
| Italy | Jan 2026 | 2% | Nil | - | AgCom levy on digital & platforms |
| Latvia | Paused | 3% | €750m | Digital interface; advertising; user data | |
| Norway | Paused | Subject to progress on OECD plans | |||
| Poland | Jul 2020 | 1.5% | Streaming media and Audiovisual media service and audiovisual commercial communication | ||
| Poland 2 | Proposed | 3% | Platform, advertising and user data services | ||
| Portugal | Feb 2021 | 1.5% | Video-sharing platforms and subscription TV streaming (1%) | ||
| Portugal 2 | Proposed | 7% | Streaming video services | ||
| Slovakia | Proposed | ||||
| Slovenia | Proposed | Advertising; user data | |||
| Spain | Jan 2021 | 3% | €3m | €750m | Advertising; user data |
| Turkey | Mar 2020 | 7.5% | TRY 20m | €750m | Advertising; Content; social media |
| UK | Apr 2020 | 2% | UK £25m | £500m | Marketplaces; Social media; search engines |
Asia Pacific Digital Services Taxes (DST)
| Country | Status | Rate | Annual sales threshold | Scope | |
| In-country income | Global income | ||||
| Australia | - | Ruled out subject to OECD negotiations | |||
| India | Jun 2016 | 6% | Rs 2cores | n/a | Advertising |
| India | Apr 2020 | 2% | INR 20m | n/a | Goods and digital services |
| Indonesia | Mar 2020 | TBC | E-commerce | ||
| Laos | Feb 2024 | TBC | Streaming; ad's; travel & hotel online | ||
| Nepal | Jul 2022 | 2% | NPR 2m | Electronic & digital services | |
| New Zealand | Withdrawn | 3% | NZ$3.5m | NZ$1.1bn | Social media; Content sharing; Search engine; user data; Intermediation; |
| Pakistan | Sep 2021 | 2% | Nil | Nil | Withholding tax on marketplaces |
| Kyrgystan | Jan 2022 | 2% | Nil | Nil | Tax on digital services B2B and B2C |
| Taiwan | Jan 2017 | WHT Digital and electronic services | |||
| Vietnam | Jan 2021 | 1.5% | Ecommerce tax WHT | ||
Africa & Middle East Digital Services Taxes (DST)
| Country | Status | Rate | Annual sales threshold | Scope | |
| In-country income | Global income | ||||
| Israel | Proposed | 3%-5% | Digital interface; advertising; user data | ||
| Kenya | Jan 2021 | 1.5% | n/a | nil | Digital interfaces services, including most non-resident e-services |
| Nigeria | Jan 2022 | 6% | NGN 25m | Content; customer data; goods & services; and intermediary services | |
| Rwanda | 2025 proposal | ||||
| Sierra Leone | Jan 2021 | 1.5% | Ad, web and data services | ||
| South Africa | Proposed | ||||
| Tanzania | Jan 2022 | 2% | Digital or electronic services | ||
| Tunisia | Jan 2020 | 3% | Apps; digital services (non-resident only) | ||
| Uganda | Jul 2023 | 5% | |||
| Zimbabwe | Jan 2020 | 5% | Digital and ecommerce | ||