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UN Draft Tax Treaty Urges Fairer Taxing Rights, Wealth Taxes

  • By James Munson

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.

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Brazil’s Tax Change to Shift Soybean Demand to US, Amius Says

  • By Clarice Couto

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.

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EU Transfer Pricing Fixes Poised to Move as Other Measures Stall

  • By Stephen Gardner

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.

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A Third of U.S. MNEs to Report More Tax Info Under EU Directive

  • By Sarah Paez

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.

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Former OECD Tax Head Doubts Global Deal Will Meet Deadline

  • By James Munson

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.

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Treasury Stares Down End-Of-Month Deadline on Global Tax Deal

  • By Benjamin Guggenheim

The Treasury Department is running into some complex disagreements over a global tax deal forged by the OECD as the end-of-June deadline to get a treaty ready for signature looms.

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House Republicans Mull Future of Tax Cuts, IRA Credits

  • By Kelsey Brugger

House Republicans hoping to extend the 2017 tax cuts are beginning to systematically examine tax provisions in the Democrats' landmark climate law.

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EU Commission to Assess Anti-Tax-Avoidance Directive

  • By Elodie Lamer

The European Commission has informed stakeholders that it will soon begin an evaluation of the anti-tax-avoidance directive, especially how it would work alongside pillar 2 of the OECD’s global tax plan.

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Malaysia Should Offer More Incentives After Pillar 2 Takes Effect

  • By Stephanie Soong

Malaysia’s 2024 budget tax incentives will benefit companies operating there, but if it wants to keep attracting investment after implementing global minimum tax rules in 2025, it must adopt further breaks, according to a new analysis.

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Unfair Allocation of Taxing Rights on Intangibles Creates Digital Divide

  • By Najeeb Memon

Najeeb Memon breaks down the global issue of how royalty income from intangibles is taxed and provides suggestions on how to close the fairness gap.

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Keeping the Promise of Carbon Taxes in Perspective

  • By Amanda Athanasiou

While the deleterious consequences of failing to limit global warming are becoming more costly, doubt has been cast on the relevance of the presumed efficiency of carbon pricing relative to green tax breaks and subsidies.

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House Republicans Aim to Zero Out OECD Funding in 2025

  • By Cady Stanton

House Republican appropriators kept their word on their intent to roll back funding to the OECD in fiscal 2025 appropriations as part of a larger protest against U.S. participation in the organization’s global tax deal negotiations.

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OECD Clarifies Risk Assessment Program Eligibility in New FAQs

  • By Lauren Vella

The International Compliance Assurance Program allows companies to preemptively discuss their transfer pricing positions with tax administrations to obtain more certainty about their tax bills.

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UK Treasury Official Sees Progress in Global Tax Treaty Talks

  • By Danish Mehboob

A UK Treasury official reported substantial progress in ironing out differences over the global tax treaty, saying it is at a point where countries can work toward adopting it.

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Proposed Buyback Excise Rules Exceed Authority

  • By Lee Sheppard

Lee A. Sheppard examines the proposed share buyback excise tax regulations and related industry feedback, and she argues that the regulations overreach and should be withdrawn.

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Spotlight on Global Minimum Taxes Shifts to Individuals

  • By Mindy Herzfeld

Mindy Herzfeld puzzles over the Biden administration’s opposition to a global minimum tax on the world’s richest people, touted as building on the success of the global corporate minimum tax.

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Liberal Democrats Pledge to Triple the U.K. Digital Services Tax

  • By Santhie Goundar

Ahead of the U.K. general election, the Liberal Democrat Party has pledged to triple the digital services tax and freeze VAT, while the Green Party and Reform UK also outlined their tax plans.

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Bahamas to Soon Propose Domestic Top-Up Tax Legislation

  • By Stephanie Soong

The Bahamian government is set to introduce draft legislation for a qualified domestic minimum top-up tax that will likely apply retroactively to January 1, according to Prime Minister and Minister of Finance Philip Davis.

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EU’s Carbon Border Levy Risks Backfiring on Industry, Study Says

  • By John Ainger

The European Union law ,meant to protect local industry from foreign undercutting in the transition to a greener economy, may do more harm than good by hindering the competitiveness of the EU industry and failing to reduce carbon dioxide emissions by the intended amount.

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Companies Ponder Their Future in Australia After Tax Crackdown

  • By Michael Rapoport

Business and trade groups that represent US-based multinationals with big Australian businesses are hearing concerns from members following the Australian Tax Office’s tough stance against multinationals they view as avoiding its taxes.  

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Biden and Trump share a faith in import tariffs, despite inflation risks

  • By David J. Lynch

Biden’s tariffs on $18 billion in Chinese electric vehicles, batteries and computer chips, announced last month, are likely too small to lift the economy’s overall price level, economists said. But Trump’s plan for 60 percent tariffs on all $427 billion in goods that China ships to the United States each year would almost certainly reshape trade in ways that consumers would notice.

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Countries Nearing Finish Line on OECD Pillar 1 Talks

  • By Stephanie Soong

Jurisdictions in the OECD inclusive framework on base erosion and profit shifting are close to finalizing pillar 1 of a sweeping two-pillar global tax reform plan, according to an update from the group’s co-chairs.

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Latin American Tax Info Exchange Brought $2.3 Billion in Revenue

  • By Sam Edwards

Exchanges of information between tax authorities in Latin America brought in an additional 2.1 billion euros ($2.3 billion) in revenue over the last five years, and other transparency measures have allowed Latin American countries to identify at least 27.8 billion euros in additional revenue since 2009.

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Australia’s Budget Puts Many Tax Issues on Multinationals’ Radar

  • By Angela Wood
  • By Andy Bubb

The Australian Budget released earlier this month had measures for multinational enterprises that ranged from barely a surprise to some game-changers from a tax administration perspective on transactions.

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Turkey Gearing Up to Implement Global Minimum Tax Rules

  • By Stephanie Soong

Turkey is getting ready to introduce OECD-brokered global minimum tax rules to protect its right to tax in-scope multinational enterprises operating within its borders, according to Turkish Finance Minister Memhet Şimşek.

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International Tax Policymaking at the United Nations: How Meaningful Will It Be?

  • By Jefferson VanderWolk

Jefferson VanderWolk cautions the international business community and developed countries not to ignore the international tax reform efforts underway at the United Nations and explains how these initiatives reveal important factors in global economic growth and what developing countries think about their taxing rights.

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Australian Budget Threatens Higher Foreign Investment Costs

  • By Amy Liu

The 2024-2025 Australian federal budget released this month continues to balance inflationary pressures with cost-of-living concerns. In this environment, specific measures on royalty tax avoidance and foreign resident capital gains tax target multinationals and foreign investors in Australia.

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UN Set to Work Out Details of Tax Treaty Amid Deep Divisions

  • By James Munson

A special committee of countries charged with creating draft terms for a global tax treaty on tax cooperation will start hashing out key details of the proposals’ shape and contents in the coming weeks, including how countries will eventually make decisions and what priority issues it will pursue.

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OECD Pillar 1 Tax Reform Negotiations at a Stalemate

  • By Stephanie Soong

Some jurisdictions are at loggerheads over transfer pricing simplification measures under pillar 1 of the OECD’s two-pillar global tax reform plan, dimming prospects of finalizing a deal in June, Italian Finance Minister Giancarlo Giorgetti said.

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Vietnam Pillar 2 Revenue to Be Funneled Into New FDI Incentives

  • By Martin A. Sullivan

Martin A. Sullivan explores developments in Vietnam’s plans for implementing pillar 2 and creating an investment support fund and incentives to drive foreign direct investment.

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OECD Calls on G7 for Further Work on Pillar 2 Dispute Resolution

  • By Stephanie Soong

Countries should keep working on approaches for resolving disputes related to global minimum tax rules and consider the legal basis for those mechanisms, such as a multilateral convention, the OECD told G7 ministers.

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Global Minimum Tax Incentive Rules Threaten US R&D Investment

  • By Lauren Vella

Unfavorable treatment of the highly lucrative US R&D credit under the global minimum tax is threatening to expose American companies to higher taxes and prompting some to rethink new investments in the US.

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Yellen Says US Isn’t Ready to Sign Pending Global Tax Agreement

  • By Condon, Christopher
  • By Viktoria Dendrinou

Treasury Secretary Janet Yellen said the US won’t sign an agreement to finalize a still-pending global tax deal until India and China agree to key unresolved issues. Yellen told reports, “India, in particular, has been a holdout and China has not really engaged very much in these negotiations at all.”

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Nations Can Fight, But There’s No Flight From Global Minimum Tax

  • By Cole, Alan

While more than 140 countries have signed on to the global minimum tax agreement known as Pillar Two, these efforts don’t always have the backing of domestic legislative bodies, some of which have done little to adopt laws that would make Pillar Two effective.

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Aligning GILTI With Pillar Two Is a Task the US Shouldn’t Delay

  • By Anne Gordon

One of the biggest questions about the global minimum tax agreement known as Pillar Two has been how different countries would implement it locally. In the US, Congress must consider the future of the domestic minimum tax on which Pillar Two is based—the Global Intangible Low Taxed Income regime, commonly known as GILTI—before the transition period to adopt the 15% tax ends in 2026.

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Divisions Persist Over Global Tax Deal’s Transfer Pricing Rules

  • By Danish Mehboob

Agreement on a few key issues under Amount B of the global tax rules has been elusive so far—such as which countries’ choice to use Amount B would be respected under the rules, which transfer pricing transactions would fall in scope, and whether the simplified rules should be optional or mandatory.

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Belgium and Italy Update Their Global Minimum Tax Rules

  • By Danish Mehboob

Italy has amended its global minimum tax law to include temporary key safe harbor provisions to simplify the application of the tax rules, while Belgium companies can now register for the tax.

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EU Warns Spain, Other Countries On Tax Law Infringements

  • By Stephen Gardner

The European Commission referred Spain to the EU Court of Justice Thursday for breaching rules on taxation in company mergers. The commission also said Germany, Hungary, Poland and Romania were infringing EU law by not sharing with other EU tax administrations data on earnings from trading via online platforms.

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EU Warns Countries On Delay in Implementing Global Tax

  • By Stephen Gardner

The European Commission is threatening to refer six countries—Poland, Portugal, Spain, Cyprus, Latvia and Lithuania—to the top European court unless they provide details of their implementation of the global minimum tax within two months.

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OECD Must Not Allow Pillar One to Erode the Arm’s-Length Standard

  • By Patton, Mike

To preserve tax fairness that underlies voluntary tax compliance, the OECD should leave room for facts-and-circumstances exceptions to part of its global tax treaty.

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Global Minimum Tax Sets up New Hurdles for Companies

  • By Lauren Vella
  • By Danish Mehboob

The global minimum tax is turning out to be a huge compliance hurdle for many multinationals, especially those with subsidiaries spread out in hundreds of cities across the globe. In order to pay their global minimum tax bill in a timely manner, large companies need to build new systems to synthesize thousands of pieces of new data and track the differences between countries’ local laws applying the levy.

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Global Tax Disputes Loom Large Without Strong Resolution Tool

  • By Lauren Vella
  • By Danish Mehboob

The design of the global minimum tax is making large multinational companies vulnerable to disputes with countries all over the world—and halfway into 2024, there’s no tool to resolve them due to the differences in adoption of the global tax rules across jurisdictions.

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US Companies Move Behind American Shield to Delay Global Tax

  • By Lauren Vella
  • By Caleb Harshberger

US multinational companies are engaging in what essentially amounts to a political game of chicken, dissolving their overseas holding companies and reshoring ownership of their subsidiaries to delay paying the new 15% global minimum tax—perhaps indefinitely.

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We are a step closer to taxing the super-rich

  • By Martin Sandbu

What once seemed like an impossibility, a global billionaire’s tax is now being considered by G20 finance ministers.

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Activists Caution New Zealand on Digital Tax Bill Reinstatement

  • By Stephanie Soong

New Zealand’s coalition government should scrap the previous government’s bill for a digital services tax because the DST could lead the country’s trading partners to respond with retaliatory tariffs, an activist group has warned.

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The EU Left Suggests a €100 Billion Windfall Tax on Monopolies

  • By Elodie Lamer

A new study by the European Left estimates that a permanent tax on excessive profitability of near-monopolies would raise between €81 billion and €107 billion.

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Lawmakers Launch Effort to Overturn Biden’s EV Tax Credit Rules

  • By James Bikales

A bipartisan group of lawmakers in the House and Senate introduced a measure to overturn the Biden administration’s rules implementing the EV tax credit, which they argue are too lenient on China.

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Kenya Calls for Repealing and Replacing Digital Services Tax

  • By Stephanie Soong

Kenya has proposed withdrawing its digital services tax and replacing it with a significant economic presence tax after President William Ruto said the government would review the DST and align it with OECD tax reforms.

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Can GLOBE Rule’s Pillar 2 Dispute Resolution Deliver Legal Certainty?

  • By Tatiana Falcao

The International Tax and Investment Center describes some potential GLOBE rule disputes and analyzes some proposals for a dispute resolution mechanism, focusing on how the tax treaty mutual agreement procedure in article 25 of the OECD model tax convention can best be used.

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The Case for Targeted Location Incentives

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah examines the use of tax incentives to encourage location-specific investment and offers a new approach that he says will be more successful.

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