Int'l Tax News

Proposed criteria that would determine who gets generous tax credits for producing hydrogen are too strict and could stifle the industry, energy companies say.

Osler’s Patrick Marley and Kaitlin Gray say Canada’s latest move to implement a digital services tax is likely to encounter political and practical challenges related to the tax itself and the OECD’s Pillar One. 

Baker McKenzie’s Juan David Velasco and Juan Diego Fernandez analyze fiscal challenges arising from economic digitization and Colombia’s recent tax reform. New regulations taking effect on Jan. 1, 2024, consider nonresidents ‘significant economic presence’ as an alternative to the OECD’s proposed guidelines for its two-pillar approach.  

Discussions on a plan for international tax cooperation under U.N. auspices is feasible, but rethinking the OECD’s two-pillar global tax reform plan would be “a giant waste of time,” a top European Commission official said.

Brazil signed into law an overhaul to simplify a patchwork of tax codes from its states and thousands of municipalities.

Robert Goulder considers Canada’s refusal to extend the global DST moratorium beyond 2023.

Kevin Brogan, Alistair Pepper, and Daren J. Gottlieb consider the implementation of the pillar 2 global anti-base-erosion rules and ways in which revisions to them may create more consistency with policy objectives.

Mindy Herzfeld looks back at key tax litigation from 2023, including Christensen v. United States.

The United States expects an extension of the pillar 1 negotiation deadline into 2024 and is working to extend the digital services tax moratorium as well, Treasury’s outgoing OECD negotiator said.

The IRS and Treasury issued further interim guidance for the corporate alternative minimum tax, addressing potential double counting of income from controlled foreign corporations and modifying prior guidance for tax consolidated groups.

The U.K. will impose a tax on imports with a big overseas carbon footprint, the government announced, in a major new commitment that aligns the country with the EU in efforts to use the global trade system to tackle climate change.

Africa could lose as much as $25 billion annually due to the European Union’s new carbon border tax, hurting the continent’s trade by penalizing valued-added exports such as iron and fertilizers, African Development Bank Group President Akinwumi Adesina said.

The 15% global minimum tax, part of the 2021 global tax pact agreed to by more than 140 countries, seeks to end the “race to the bottom” that has nations competing to offer the lowest corporate tax rates to draw big business investment to their shores.

Australia started consultations with digital service providers to inform them on global minimum tax implementation plans, data requirements, and potential solutions for future compliance.

The United Nations’ framework for international tax cooperation is likely to initially include tackling illicit financial flows and cross-border services, two key areas of concern for developing countries, a UN official said.

The Kingdom of Saudi Arabia is aiming to transform into a significant business hub, attracting a growing influx of foreign companies.

The Biden administration released long-awaited rules designed to block electric-vehicle manufacturers from sourcing battery materials from China and other foreign adversaries, while giving automakers some flexibility to comply with the new mandates.

The Biden administration issued new rules to prevent Chinese firms from supplying parts for electric cars set to receive billions of dollars in tax credits.

The chair of the EU Code of Conduct Group on business taxation said implementation of pillar 2 probably won’t become a determining factor for the list of noncooperative jurisdictions until after the peer review.

House taxwriters unanimously advanced a fix to the issue of double taxation with Taiwan, moving a unique bill combining approaches from two Senate committees.

Tax measures put in place by EU countries will face closer scrutiny beginning next year for their possible harmful effects on other member countries’ economies, the chair of the bloc’s Code of Conduct Group (Business Taxation) told the European Parliament tax subcommittee.

More pillar 2 guidance is likely to be published by the end of 2023, including advice on the peer review process and on antiabuse rules related to a key safe harbor, a top Treasury official said.

The European Commission has decided against proposing a directive to implement pillar 1 of the OECD’s two-pillar global tax reform plan because the pillar 1 multilateral convention would be enough, an EU official said.

A minister from Barbados discouraged countries from blacklisting others based on how far they’ve developed their tax transparency frameworks.

European Union countries are largely on track to start applying Pillar Two of the global tax deal next year, but the finalization of Pillar One remains uncertain, an EU official said at a European Tax Adviser Federation seminar.

Tax talks that would combine a beefed-up child tax credit and reinstate full research and development expensing aren’t exactly sizzling, but they are picking up speed after a year in the doldrums.

The UK’s projection of £12.7 billion ($15.9 billion) in revenue within the next six years from the global minimum tax is highly uncertain, a top budget economist told lawmakers in a government budget hearing Tuesday.

The Austrian, Norwegian, and Slovenian governments have proposed legislation implementing an EU directive for adopting global minimum tax rules under pillar 2 of the OECD’s two-pillar global tax reform plan.

Martin A. Sullivan explores financial data for more than 300 multinational companies to uncover trends in intellectual property transfers.

The United Kingdom will make full expensing for business capital investments permanent as part of a plan to invest £20 billion annually in businesses over the next decade, said Chancellor of the Exchequer Jeremy Hunt.

U.N. countries passed a resolution in committee to establish a framework convention for international tax cooperation, which would shift negotiations from the OECD to the U.N.

While EU countries generally reacted positively to the Spanish EU Council presidency’s proposal exempting comprehensive withholding tax relief systems from some Faster and Safer Relief of Excess Withholding Taxes provisions, several requested time to study the impact.

Colombia will seek to allow arbitration in tax disputes for the first time in a major step forward, although questions remain about the proposal’s efficacy, tax professionals say.

The UK government estimates it will net about £12.7 billion ($15.9 billion) from the global minimum tax over the next six years, according to figures published in its Autumn budget statement.

The U.K.’s top financial official, Jeremy Hunt, outlined measures to spur business investment and push more people into jobs.

Nana Ama Sarfo discusses Barbados's changing approach to pillar 2.

Despite opposition from business groups and the Biden administration, Canada has confirmed its intent to move ahead with its digital services tax just weeks before its planned effective date.

A draft resolution released by the UN calls for the development of a framework convention to make international tax cooperation more inclusive.

Income tax rates for companies have decreased on average over the past 23 years, according to a report on corporate tax statistics released by the OECD on Tuesday.

A note prepared by the EU Council's Spanish presidency suggests pursuing the European Commission's idea to maintain the tax consequences of its proposal to tackle the misuse of shell entities.

The cost of government support for electric vehicle battery manufacturing projects in Canada that includes U.S.-credit-matching subsidies to major automakers could exceed estimates by almost C $6 billion, a budget watchdog said.

Switzerland may postpone raising the minimum tax rate on multinationals to 15%, amid widespread delays in implementing a global deal on the issue.

The United States has joined 13 other countries from the Indo-Pacific region in agreeing to, among other measures, strengthen cooperation to combat cross-border tax evasion.

The Bermudian government is holding a third consultation on its proposed corporate tax regime — this time on draft legislation intended to align with the global anti-base-erosion rules under pillar 2.