Int'l Tax News

The announcement that Canada would rescind its digital services tax a day before initial tax returns and payments were due leaves open questions for taxpayers who would have been subject to that tax, including the availability of refunds for any taxpayers who may have already paid, as well as about the future course of Canadian tax policy.

Countries in a United Nations committee remain divided over how a new treaty should revamp global tax rules, including how to redistribute the allocation of taxing rights.

The future of France’s digital services tax is in the hands of the French Constitutional Council, which will soon determine whether the controversial measure is unlawful.

The Australian Productivity Commission has advised cutting the corporate tax rate to 20 percent for most businesses to encourage investment and lift productivity in the country.

Cyprus has recently enacted significant amendments to its tax legislation, introducing robust defensive tax measures aimed at countering aggressive tax planning involving low-tax jurisdictions and non-cooperative jurisdictions, often referred to as “blacklisted” jurisdictions (BLJs).

Pakistan has rolled back its newly enacted digital presence proceeds tax on companies operating outside the country in an apparent concession to the United States for securing an oil reserves development deal.

 Mindy Herzfeld examines the One Big Beautiful Bill Act’s changes to the international tax regime, saying that while the regime’s foundation remains mostly intact and the changes are generally improvements, some of them interact in unexpected ways that taxpayers should consider carefully.

France will respect the application of the simplified and streamlined transfer pricing approach by a low-capacity jurisdiction with which it has a bilateral tax treaty in force, in line with the amount B political commitment.

The intensity of EU member state involvement in the U.N. tax talks could hinge on whether the EU delegation is allowed to join intersessional workstreams.

Reuven S. Avi-Yonah compares House and Senate sections of the One Big Beautiful Bill Act and examines the potential effect on international tax

Mark R. Martin, Cameron Taheri, Mark J. Horowitz, Thomas D. Bettge, Caroline Conway, and Caleigh Wallace outline the IRS’s annual report on advance pricing agreements and offer country-specific insights for taxpayers navigating the evolving global tax landscape.

Source countries — often developing countries or emerging economies — are advocating for a U.N. tax convention protocol that enables the taxation of cross-border services without permanent establishment.

Ryan Bray, Matthew Brown, and Jose Rego argue that the removal of proposed section 899 from the One Big Beautiful Bill Act might not make things as simple for some U.S. taxpayers as it first appeared, saying uncertainties remain after the agreement between the United States and the other G7 countries.

Elizabeth J. Stevens and J. Clark Armitage critique Treasury regulations and IRS guidance governing periodic adjustments to the pricing of transfers of intangible property, and they analyze ways for controlled taxpayers to adapt to and mitigate the risk of such adjustments.

Mexico still plans to implement the OECD’s amount B simplified and streamlined approach, and South Africa is interested in doing the same, according to a new batch of updated OECD transfer pricing profiles.

Larissa Neumann and William R. Skinner review the One Big Beautiful Bill Act ramifications and the Facebook and Yum! Brands Inc. cases and explore the status of recent regulations and guidance.

The tax guidance multinational corporations and international tax practitioners want to see most has nothing to do with the sweeping new tax law that was just enacted.

Lucas Martini de Aguiar analyzes the potential impact of new Brazilian legislation on nonresident investment in the stock market.

Lee A. Sheppard examines a provision in the One Big Beautiful Bill Act that restores, with some exceptions for specified foreign parent situations, the prohibition on downward attribution that the Tax Cuts and Jobs Act repealed, saying that the IRS and Treasury will need to rescind or reengineer guidance issued while the prohibition was repealed.

The G20 will keep negotiations going on a proposal to shield U.S. companies from the application of some OECD pillar 2 global minimum tax rules, according to a communiqué issued after a key meeting.

Several EU member states said it is not within the EU's competence to collect a financial contribution from companies to finance the bloc's budget and that such a measure would harm competitiveness.

G20 finance ministers and central bank governors issued a communiqué following their July 17-18 meeting in South Africa, noting their continuing commitment to improving international tax cooperation by addressing concerns regarding global minimum taxes under pillar 2 of the OECD’s two-pillar global tax reform plan.

The White House says the EU is committed to abandoning its future plans to impose network fees on big U.S. tech platforms; the European Commission is less sure.

The IRS and Treasury are contemplating the proper attribution method to determine the source of income for cloud transactions and are questioning how to evaluate relevant factors like intangible property.

Patrick Driessen argues that the similarity between the U.S. base erosion and antiabuse tax and digital services taxes undermines the United States’ criticism of DSTs.

Adam Kern analyzes how treating global intangible low-taxed income as an income inclusion rule will affect the stability of pillar 2.

The OECD on July 17 published a report — prepared ahead of the July 17-18 meeting of G20 finance ministers and central bank governors in South Africa — regarding recent developments in international tax cooperation, including its support of various G20 priorities such as tax transparency and the implementation of the base erosion and profit-shifting minimum standards.

The OECD plans to adapt its transfer pricing guidelines to new realities like global mobility and artificial intelligence and to develop a common understanding of terms that are often disputed, an official said.

The lines between tax and trade policy are likely to become increasingly blurred as the Trump administration shifts its attention to disarming overseas digital services taxes, observers say.

The U.N. tax framework convention’s early protocol on services should incorporate fractional apportionment or formulary apportionment similar to amount A of pillar 1 of the OECD’s two-pillar global tax reform plan, the G24 said.

The design of an own resource to finance the EU budget as a contribution levied on high-turnover companies raises legal questions.

Pramod Kumar Siva and William H. Byrnes explain why the UTPR, formerly known as the undertaxed profits rule, is an unlawful extraterritorial tax that contravenes legal norms, generates economic distortions, and diminishes international tax cooperation.

A new Eurobarometer shows that 80 percent of Europeans polled want large multinational enterprises to pay a minimum amount of tax in each of their countries of operation, an idea that finds a majority in all member states.

Muhammad Ashfaq Ahmed examines changes to the U.N. Model Tax Convention 2025 from their genesis, evolution, and development, to their finalization, approval, and future implications from both an international tax law and international political economy perspective.

Mindy Herzfeld examines the developments that led to the recent G7 agreement to respect the U.S. tax regime as “a side-by-side system” with the OECD’s pillar 2 and what that means for the future of digital services taxes and tax multilateralism more broadly.

The EU has “a quite negative view” on the United States' proposal to credit its minimum tax rules when calculating their qualified domestic minimum top-up taxes under pillar 2, according to a top European Commission official.

In a letter to the editor, Jefferson VanderWolk argues that pillar 2 should be abandoned rather than an attempt be made to salvage it.

Nana Ama Sarfo discusses Nigeria's new tax reform legislation and its emphasis on base broadening and tax enforcement.

Robert Goulder comments on the recent G7 agreement regarding pillar 2 and the withdrawal of proposed section 899.

Governments across the globe breathed a sigh of relief when Republicans dropped section 899, but slow progress on the terms of the deal reached by the G7 could see it return with a vengeance.

Germany’s economy minister has rejected the idea of imposing a digital tax on U.S. technology companies that the minister of state for culture had said the government was drafting in May.

Irish Finance Minister Paschal Donohoe said there are still outstanding questions about how the G7 deal on pillar 2 will affect competition between the EU and the United States and the future of the law.

The European People’s Party's advocate for copyright issues in the European Parliament has suggested a 7 percent levy on artificial intelligence companies that use copyright-protected works to compensate rightsholders.

BRICS member states said they support work on a U.N. tax convention and its role in promoting better cooperation and transparency to address issues like illicit financial flows and tax evasion by the superrich.

Simone Decè considers whether implementing a global wealth tax is practical, analyzing the challenges that different proposed solutions present.

Martin A. Sullivan examines the foreign-derived deduction-eligible income provision in the reconciliation bill.

Several high-income countries and civil society groups committed to improving developing countries' domestic tax systems to increase revenue collection there at a major U.N. development financing conference.

Lucas de Lima Carvalho examines the status of the OECD’s multilateral instrument in Argentina and Peru.

Nana Ama Sarfo reviews the tax-related provisions of the outcome document from the U.N.'s Fourth Financing for Development Conference and the Sevilla Platform for Action.

 Foreign investors that reinvest their dividends from Chinese entities into qualifying domestic companies will be allowed a 10 percent tax credit, the government announced June 30.