On September 25, some of the world’s top tax professionals gathered for a day of thought leadership and discussion on the evolving complexities of international tax law. The one-day summit, FUSION 2025, featured panelists from three different continents and seven countries — covering topics such as Pillar 2 updates, the impact of global trade wars, and trends among auditors in various regions of the world.
Below, we’re sharing some insights from a panel discussion on the fast-shifting landscape of international customs. With the recent imposition of a broad swath of tariffs by the U.S. government, here’s a look at how companies, auditors, and tax officials around the world are reacting. The panelists for this session were Tung Nguyen, an Associate at BakerHostetler (U.S.); Najat Akodad, a Partner at WTS Global (France); Eugene Lim, a Founding Principal of Taxise Asia (Singapore); Martin Ng, a Managing Partner of WTS China (China); and Amy Reville, a Tax Professional at Sabios (Ireland).
The Evolving Landscape of U.S. Tariffs
Tung Nguyen, an international trade attorney at BakerHostetler, set the stage by acknowledging the obvious: There’s a lot of uncertainty about which tariffs imposed by the Trump administration will last and which will fade due to court challenges and political pressure. But Nguyen’s best guess is that many of the tariffs will remain in place. “I think it is clear that there will be a multi-tier tariff system in the U.S. in the long term,” he said.
Right now, there are a lot of moving pieces to U.S. trade policy, including:
- Reciprocal tariffs — corresponding to another country’s own taxes on imported goods
- Sectoral tariffs — targeting steel, aluminum, robotics, machinery, and other strategic goods
- Traditional unfair practices — such as anti-dumping rules and countervailing duties, which the U.S. government has long imposed on some imports
According to Nguyen, an America First trade policy isn’t going anywhere. He forecasted three tiers of tariffs going forward: 0-15% for close allies of the administration, 20-25% for cooperating partners, and a punitive tier of 40-50% for non-cooperating nations. In other words: Even if the legal basis for tariffs needs to shift, the tariffs themselves will remain firmly in place.
France and Europe Are Recalibrating
French and EU companies have been forced to move from a wait-and-see stance to a place of action, even as negotiations continue between Europe and the U.S. For now, both sides have agreed to a 15% tariff cap, allowing companies to begin preparing for what lies ahead.
Najat Akodad emphasized that companies are now:
- Assessing added costs across their portfolios
- Re-evaluating industrial processes
- Considering partial production shifts into the U.S.
- Exploring partnerships to reduce risk
- Testing operational alternatives and new markets
At the EU level, retaliatory measures against U.S. goods — such as soybeans, denim, and motorcycles — are prepared but currently suspended, adding uncertainty to an already volatile environment.
Why Ireland Is Watching Especially Closely
For Ireland, this is more than a trade story — it’s a national economic issue. Amy Reville explained that Ireland relies heavily on exports, particularly pharmaceuticals. In fact, of the EU’s 2024 trade surplus with the U.S. (about €200 billion), nearly a quarter of that (€44 billion) came from the pharmaceutical sector in Ireland alone.
Branded pharmaceuticals, which represent the bulk of Ireland’s export engine, are not currently exempt from U.S. tariffs. Negotiations continue, but the potential outcomes will have massive consequences for Irish companies’ bottom lines. The Irish government has responded with an action plan to promote market diversification and address heightened anxiety.
Reville highlighted two aspects of the action plan that are especially relevant to companies. The government is offering grants of €35,000 for firms to research the impact of tariffs on their businesses, and another grant of €150,000 for companies to investigate diversification efforts by exploring new markets and products.
China’s Strategic Response: More Than Tit-for-Tat
Many people interpret the U.S.-China trade war as a punch-and-counterpunch affair, but Martin Ng urged the audience to pay attention to China’s long-term strategy and policies governing international trade. While there have been reactionary measures taken in response to the Trump administration, the Chinese government also follows its own Five-Year Plans — published blueprints for economic and social development — and takes those very seriously.
There will be a new Five-Year Plan released in early 2026, but Ng noted that it will likely borrow heavily from the existing one, which includes tax and trade priorities such as:
- Consolidation of Trading Zones: China has merged thousands of special economic areas into 22 comprehensive zones designed to test innovative customs, tax, and foreign-exchange policies.
- The Rise of Hainan Island: On December 18, China will officially launch what may become the world’s largest bonded zone, with zero duty on goods processed at least 30% on the island, special customs privileges, and ambitions to become a major hub for global trade.
- Anti-Circumvention Law: China is preparing legislation targeting companies that shift minor processing to third-world countries to avoid tariffs. Even before the law’s enactment, a U.S. company was penalized for reclassifying optical fiber products, showing Beijing’s seriousness.
- More Offshore Trading: China wants to replicate Hong Kong’s dominance in “offshore trade” — transactions between non-Chinese parties facilitated by a Chinese entity. Once foreign exchange controls relax, this could create major opportunities for global companies with Chinese subsidiaries.
Risks, But Also New Competitive Advantages in Singapore
Eugene Lim provided a pragmatic view from Asia. While uncertainty about the tariff landscape initially created anxiety, many companies are now spotting opportunities. Once you factor in the full spectrum of tariffs, including reciprocal ones, the competitive equation appears to be changed for some countries in Asia. According to Lim, the shift has encouraged companies to:
- Reconsider where they manufacture for U.S.-bound goods
- Explore contract manufacturing in places like Korea
- Use first-sale valuation strategies
- Examine long-term options for moving production out of China
That said, greenfield investments remain rare due to uncertainty, Lim said: “Even if you started setting up a new facility or a new plant today, by the time the plant is ready for commissioning, it might be the end of the Trump administration.”
What Companies Should Do Now: A Practical Playbook
The panel concluded with some actionable advice for companies. Though the exact needs and tools at their disposal depend on a firm’s unique profile, the panelists offered a general playbook to follow:
- Conduct granular, product-specific tariff exposure analysis.
- Explore valuation strategies: First-sale rules, unbundling, and transfer pricing alignment can reduce the duty base.
- Reassess your manufacturing footprint. Potentially, moves to Southeast Asia — or within Asia — can materially change tariff exposure.
- Leverage free trade agreements like the Regional Comprehensive Economic Partnership (RCEP). Its “cumulation” rule allows value to be accumulated across member countries, potentially qualifying goods for dramatically lower tariffs when sold into China or ASEAN countries.
- Strengthen origin compliance. With more audits on the way and a five-year U.S. lookback window, record-keeping is critical.
- Build proactive audit and compliance programs. Both U.S. and Chinese authorities are sharpening enforcement on misclassification, valuation, and illicit transshipment.
- Monitor policy constantly. Trade rules are changing fast!
How GTM Can Help
There are many moving parts in this new international tax and trade landscape. The need for contingency planning, modeling, and reviewing global structures is at an all-time high.
At GTM, we offer a range of tax solutions and industry-leading expertise. Our team is available to walk clients through policy shifts, technology and automation solutions, and tax filings on your behalf or through a collaborative structure.
Learn more about the tax solutions we’ve brought to clients here. Reach out to GTM today to discuss how to prepare effectively for your tax future.
