Int'l Tax News

The OECD has released a package of pre-application templates to assist multinational groups with their international compliance assurance program applications, which must contain specific information and overviews of transactions.

The OECD is already eyeing other pressing profit attribution issues, including those related to global mobility, now that only minor items for a mandatory amount B still need to be negotiated, an OECD official has said.

A corporate proposal for a permanent country-by-country reporting safe harbor under the pillar 2 global anti-base-erosion rules could help make the EU more business friendly, according to a European Commission official.

The OECD is working on identifying jurisdictions that are planning on adopting the optional amount B transfer pricing simplification framework and will likely release a list in October, an OECD official said.

The European Commission’s tax decluttering and pro-competitiveness agenda will probably enhance its business-friendly image and build a bridge between pillar 2 and the anti-tax-avoidance directive, an EU official said.

Multinational enterprises may have reduced their base erosion and profit-shifting activity in the past few years, but the practice is still ongoing, according to the most recent country-by-country reporting data.

Three multinational music streaming companies have mounted a challenge to a Canadian streaming services tax in federal court, according to a digital music advocacy group that claims the levy is bad policy.

The European Parliament’s political groups have decided that a member of the Left Group will succeed Paul Tang as chair of the EP’s subcommittee on tax matters.

Hong Kong’s government has gazetted legislation establishing a patent box granting preferential tax treatment for qualifying income from intellectual property and IT.

In this symposium paper, the UF Tax Incubator working group examines the U.S. approach to taxing income earned through foreign branches, and it explores ongoing issues and potential reforms.

Business groups are sounding the alarm on potential trade and economic damage from Canada’s digital services tax following the issuance of a coming-into-force order by the Canadian government.

Robert Goulder comments on the new EU tariffs directed at Chinese EVs.

The view that low taxation increases investment is evolving, according to the European Commission, raising the question whether corporate tax can influence EU countries' competitiveness.

Netflix, Walt Disney, and other U.S. streaming companies have asked a Canadian court to stop plans by authorities to force them to fork over 5% of their sales in the country to finance local broadcast news and other domestic content.

Canada authorized the implementation of a digital-services tax, a move that threatens to trigger trade retaliation from Congress and the Biden administration.

Nana Ama Sarfo reviews the latest research commissioned by the South Centre, African Union, African Tax Administration Forum, and West African Tax Administration Forum into the amount of revenue developing countries might raise from amount A versus a digital services tax.

Introducing a global minimum tax rate for the largest multinational enterprises is a “catastrophic failure” because it burdens businesses and dampens EU competitiveness, according to Hungarian Prime Minister Viktor Orbán.

The end-of-June deadline for countries to conclude pillar 1 tax reform negotiations has come and gone, but delegates are still making good headway toward a final agreement, the OECD’s tax director said.

India has joined the group of countries that have extended the “unilateral measures compromise” with the United States that outlines a transitional approach to their digital services taxes before pillar 1 rules are implemented.

Nathan Boidman, Michael N. Kandev, and Marc André Gaudreau Duval, in the first installment of a two-part analysis, provide an overview of, and context for, the Global Minimum Tax Act — legislation now moving through Canada’s Parliament to implement pillar 2. Part two will more closely examine certain aspects of the legislation with a focus on provisions that yield interpretational issues or deal with antiavoidance.

Hafiz Choudhury explains efforts at the U.N. to foster an international taxation cooperation process more inclusive of developing countries. The opinions expressed in this article are solely those of the author and do not reflect the views of any other person or organization, in particular the U.N.

Aditi Goyal and Kanupriya Sharma explore the concept of “virtual permanent establishment” as a framework for taxation in an increasingly digital world, using the Clifford Chance case in India as a primary example.

More OECD focus on developing permanent safe harbors for pillar 2 minimum tax rules could decrease the need and volume of administrative guidance going forward, according to an OECD tax official.

High-income countries should engage constructively in U.N. discussions to develop a framework convention on international tax cooperation or risk a global spread of tension in tax policymaking, a top EU tax official said.

The U.S. is set on making Amount B, which deals with companies’ marketing and distribution activities, mandatory even as several other countries are pushing to make it optional.

The Canadian Parliament has passed a highly controversial 3 percent digital services tax on large businesses, sparking calls from U.S. trade groups for Canada to reconsider.

Policymakers have spent more than a decade crafting an international consensus on the allocation of corporate tax revenue, but the scattered landscape for settling tax cases could undermine the goal of a smoothly operating system.

The dispute, which was closely watched by experts, involved a one-time foreign income tax, but many saw it as a broader challenge to pre-emptively block Congress from passing a wealth tax.

The court rejected a challenge from conservative activists to a one-time tax on certain foreign investments but left unresolved questions about whether some leading Democratic revenue-raising ideas are constitutional.

Mindy Herzfeld examines what countries are doing to maintain competitiveness as pillar 2 makes offering fiscal incentives a fraught undertaking.

The leaders of the G7 countries are aiming to open the pillar 1 multilateral convention for signature by the end of June.

Young Ran (Christine) Kim with Cardozo School of Law and Darien Shanske with the University of California, Davis, continue their argument that a digital barter tax is a good idea and examine possible legal arguments and challenges.

Turkish lawmakers have drafted new tax proposals aimed mostly at companies, seeking to repair a budget buffeted by last year’s earthquakes, in what would be the biggest overhaul in a generation.

Norway’s planned clampdown on the nation’s wealthiest citizens is provoking a backlash from entrepreneurs who warn the measure will just worsen the economy’s heavy dependence on oil and gas.

In a communique at their summit in Italy, the G-7 leaders said they hope the treaty will be open for signature by the end of June, as OECD officials have said. The G-7 leaders also called for further progress on the implementation of the OECD’s global minimum tax.

Turkish Finance Minister Mehmet Simsek said the government has postponed plans to introduce a “very limited” transaction tax on stock trading, after push back from traders.

Sir Keir Starmer, UK opposition party leader, set out plans to raise £8.6bn in tax in the Labour manifesto on Thursday as he promised to “relight the fires” of economic growth and bring “Conservative chaos” to an end.

The Danish government presents a plan to significantly lower taxes for entrepreneurs, in a move to bolster the startup scene in the Nordic country, particularly in the biotech industry.

Saudi Arabia laid out a series of steps it plans to take to boost its debt capital market, including a possible easing in taxes it hopes will make local corporate bonds more appealing to foreign investors.

According to new research from Oxford university, the world’s largest private capital firms have avoided income taxes on more than $1tn in incentive fees since 2000 by structuring the payments in a way that subjected them to a much lower levy.

The European Commission has added fair and efficient taxation, cross-border taxation, and double nontaxation to its renewed Platform for Good Tax Governance and is accepting applications for membership to its new expert group.

Canadian Conservative Leader Pierre Poilievre said he would vote against the government’s proposal to raise the capital gains tax inclusion rate, ending weeks of speculation about where he would land on the issue.

Digital services taxes would generate similar revenue for countries to those under the global minimum tax, according to research from an intergovernmental organization of developing countries.

A coalition of technology and industry associations with business ties to Canada asked the Office of the U.S. Trade Representative to initiate a formal trade dispute in an effort to block Ottawa’s digital services tax.

A new U.N. framework convention could include high-level commitments on the fair allocation of taxing rights among countries, including the taxation of multinational enterprises and high-net-worth individuals.

A UN committee has provided countries with a preliminary document for negotiating a global tax treaty, naming fair taxation of corporations and wealth taxes as areas of focus.

A surprising tax change in agriculture powerhouse Brazil has the potential to make soy grown in the world’s largest bean exporter less competitive with supplies from the US, according to a report from risk management firm Amius Ltd.

A draft European Union law on transfer pricing may have the best chance of moving forward before the end of the year in what is likely to be a slow season for EU tax rulemaking.

Around a third of large U.S. multinational enterprises will be required to publish more disaggregated financial information than previously mandated in light of new EU public country-by-country reporting rules.

The OECD missed its initial March deadline to finish talks on Pillar One and faces tough opposition in trying to get the agreement to the finish line by the end of June.