If Section 899 of the One Big Beautiful Bill survives the US Senate intact, the American threat to the tax sovereignty of other countries would be explicit and concrete.

That is the view of Alex Cobham, an economist and chief executive of the Tax Justice Network.

He has been a researcher focused on illicit financial flows, effective taxation for development and inequalities, variously at Oxford University, Christian Aid, Save the Children and the Centre for Global Development.

He has been closely watching the Organisation for Economic Co-Operation and Development and its efforts at crafting an agreement in international tax co-operation.

The OECD’s yearslong pursuit of its global tax agenda is what has led to Bermuda’s share in the much vaunted corporate income tax.

In the US, particularly in conservative circles, there has long been concern that US multinationals and the US Government would be the big losers of the OECD policy.

US president Donald Trump was barely back in office when he issued a salvo against the OECD’s Global Tax Deal, an agreement that overhauls how multinational corporations are taxed.

Mr Trump fired off a memo on his first day to senior treasury and trade representatives and to the US office at the OECD, “clarifying that the Global Tax Deal has no force or effect in the United States”.

He ordered an investigation into foreign countries that “are not in compliance with any tax treaty with the United States or have any tax rules in place, or are likely to put tax rules in place that are extraterritorial or disproportionately affect American companies”.

Meanwhile, Mr Cobham has written books on global tax subjects, including his latest from last year: What Do We Know and What Should We Do About Tax Justice?

He told The Royal Gazette yesterday: “Given that on average US multinationals systematically avoid or evade tax in most jurisdictions where they operate, and that US multinationals tend to be the largest tax-abusive actors in most economies around the world, it is almost inevitable that governments’ efforts to curb corporate tax abuse will fall clearly on US multinationals [as well as others].

“These measures seek to exert taxing rights on profits arising locally that would otherwise be shifted out, eroding the local tax base.

“As a result, almost any such effort runs the risk, and increasingly the near certainty, of being deemed ‘discriminatory’ [because US multinationals will be among the most affected due to their leadership of tax abuse] and/or ‘extraterritorial’ [because profits that have been or would have been shifted out will be affected, in some sense].

“And so Section 899 is the clarification of the threat we have highlighted since [Mr] Trump’s Day 1 executive memo: governments around the world have a clear choice between allowing this US regime simply to remove their tax sovereignty in this important area, and the associated public revenues, or to seek to defend themselves.

“In the latter case, the negotiations of the UN tax convention are the best and perhaps only opportunity to act collectively against the unilateral threat posed by the Trump Administration.”

There are also indications that it can be a losing bet.

The UN general assembly voted almost overwhelmingly in November to begin creating a new, global tax regime.

Countries who sought to block the efforts months earlier included Britain and the US, plus Australia, Canada, Israel, Japan, New Zealand and South Korea.