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Int'l Tax News

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Australia Seeks New Penalty on Companies Avoiding Royalty Taxes

  • By Michael Rapoport

Australia plans to introduce a new tax penalty for big companies that try to avoid taxes on royalties in its latest move to crack down on multinationals that it says aren’t paying their fair share.

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EU Ministers Agree on Withholding Tax Rule, Stumble on VAT

  • By Stephen Gardner

European Union finance ministers agreed in principle to a law intended to speed up cross-border withholding tax refund procedures and that will require EU countries to replace current tax refund systems for cross-border dividend and interest payments with improved, simpler procedures.

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Biden administration to increase tariffs on Chinese electric cars to 100 percent

  • By Bukryk, Zack

The Biden administration will increase tariffs from 25 percent to 100 percent on Chinese EV imports to offset Chinese export practices, which they argued “favor Chinese automakers at the expense of U.S. and other foreign automakers and autoworkers and are leading to a massive surge of unfairly underpriced Chinese vehicles into foreign markets.”

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Will Singapore’s Refundable Investment Credit Trigger Pillar 2 Tax?

  • By Martin A. Sullivan

Martin A. Sullivan scrutinizes the no-benefit requirement under pillar 2 of the OECD’s base erosion project, highlighting the tension between incentives and taxation in light of Singapore’s planned implementation of two components of pillar 2.

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Seeking Cover: A Path to Challenge Digital Services Taxes in Ireland

  • By Tomás Bailey, Colm Brussels, and Rachel O’Sullivan

Tomás Bailey, Colm Brussels, and Rachel O’Sullivan explain how Irish taxpayers can use the EU tax dispute resolution directive to challenge the tax treaty compatibility of EU member states’ digital services taxes.

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N Ireland should cut corporate tax to boost growth, says business lobby

  • By Jude Webber

Northern Ireland should slash its corporate tax rate from 25% in line with the Republic of Ireland’s 12.5% rate for small firms and 15% for large companies, to drive growth in the cash-strapped region.

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Can Investment Treaties Defeat Pillar 2?

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah casts doubt on whether bilateral investment treaties offer investors a viable shield from pillar 2’s qualified domestic minimum top-up tax, in response to a recent Tax Notes article.

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China Mulls Dividend Tax Waiver on Hong Kong Stocks Connect

  • By Bloomberg News

Regulators including the China Securities Regulatory Commission and the State Taxation Administration are reviewing a plan submitted by Hong Kong to waive the 20% tax on dividends from Hong Kong stocks bought via Stock Connect.

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Norway Risks Outflow of Startups Dismayed by Harsher Exit Tax

  • By Ott Ummelas

The Norwegian government in March announced its latest step to close tax loopholes for wealthy expatriates by setting a deadline for the payment of an exit tax on unrealized changes in the value of their assets, or their transfer. That plan follows increases in wealth and dividend taxes since 2022 that have prompted dozens of the country’s richest to relocate, mainly to Switzerland.

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EU Examining Ways to Improve Tax Information Exchange Process

  • By Stephen Gardner

The European Commission is evaluating the effectiveness of reporting rules that govern collection of information relevant for cross-border taxation and the exchange of that information between EU tax authorities.

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Groups Seek Disclosure Protection for Australian Tax Reporting

  • By Lauren Vella

Financial services industry groups are calling on the Australian government to be more discerning with the tax information from funds that is made public following it’s country-by-country proposal released in February.

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Governments slap taxes on EVs as $110bn fuel duty shortfall looms

  • By Smyth, Jamie
  • By Amanda Chu

Global policymakers, including the UK, New Zealand, Israel and US states, are imposing new taxes on electric vehicles as the shift away from combustion engines threatens to leave a $110bn hole in government revenues owing to a drop in receipts from fuel duties. 

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Protecting the U.S. Tax Base: Roundtripping and IP Sales

  • By Mindy Herzfeld

Mindy Herzfeld explains the uneven effect of the Tax Cuts and Jobs Act’s carrot-and-stick approach to encouraging U.S. multinationals to bring valuable intellectual property back to the United States.

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Firms Likely to Set Up PEs in Countries With Digital Taxes

  • By Stephanie Soong

Companies in scope of digital services taxes will probably have more permanent establishments in jurisdictions with DSTs if OECD pillar 1 rules are enacted, according to a Joint Committee on Taxation economist.

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European Countries Differ on Treaty Application for Remote Work

  • By Sarah Paez

EU member states are at odds over how to coordinate the application of double taxation agreements to accommodate the tax complexities of cross-border telework.

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Treasury Looks to Cut Out Foreign Supply Chains With EV Credits

  • By Alexander Rifaat and Mary Katherine Browne

Manufacturers have two years to move their critical mineral supply chains away from foreign entities of concern if they want to qualify for the new clean vehicle tax credits, Treasury announced in final regulations.

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Tax and Non-Tax-Related Challenges of Pillar 2 for Non-Advanced Economies


Błażej Kuźniacki and Edwin Visser explain the difficulties for non-advanced economies trying to attract foreign direct investment while also adhering to new pillar 2 rules, and offer suggestions for new international approaches that could help create a more level playing field for all economies.

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Corporate Loss Deduction Hangs in Balance Under Global Tax Deal

  • By Lauren Vella

US multinational companies may lose the ability to deduct up to hundreds of millions of dollars’ worth of losses incurred from their income starting this year under the new global minimum tax.

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Canadian Digital Tax May Cost U.S. Firms $2 Billion Annually

  • By Stephanie Soong

Canada’s digital services tax might cause U.S. companies to lose up to $2.3 billion annually, and if the United States doesn’t push back, the “global contagion” of DSTs will spread, a tech industry group said.

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Let’s Play Fair: Reconsidering the U.S. Corporate Tax System

  • By Roy Clemons

Roy Clemons argues that the United States should replace its quasi-territorial tax system and proposes a framework that taxes domestic and multinational corporations at the same statutory tax rate on a country-by-country basis.

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Withdrawing Cost-Sharing Regulations Would Achieve Little

  • By Ryan Finley

Ryan Finley explains why withdrawing the cost-sharing regulations wouldn’t further the policy goals of cost-sharing critics.

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Pillar 1: Seeking Justifications That Aren’t There

  • By Robert Goulder

Robert Goulder comments on a recent Congressional Research Service report on pillar 1 and digital services taxes.

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Startling Results From Recent Country-by-Country Reports

  • By Martin A. Sullivan

Martin A. Sullivan examines newly released IRS data that reveal surprising shifts in where U.S. multinationals book profits and losses, with some of the usual suspects absent and Gibraltar topping the tax haven list.

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Honda Eyes New Canadian Tax Credits for C $15 Billion Investment

  • By Amanda Athanasiou

Honda is the latest automaker to announce a multibillion-dollar investment in Canada, bolstered by new investment tax credits introduced by the federal government to support the green transition.

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Amount A Impact Analysis on U.S. Corporate Tax Revenue — A 2024 Update

  • By Vladimir Starkov and Alexis Jin

Vladimir Starkov and Alexis Jin explain their study on the effect of amount A on U.S. corporate income tax revenue.

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EU Calls on UN to Avoid Duplicating Global Tax Discussions

  • By Stephen Gardner

A future United Nations Framework Convention on International Tax Cooperation should help countries reform their domestic tax systems and avoid duplicating work on international tax reform, the European Union said ahead of UN tax discussions in New York.

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UN Committee Begins Drafting Global Tax-Cooperation Plan

  • By Michael Rapoport
  • By Lauren Vella

The committee is considering topics such as how the UN framework will approach taxing multinational companies and wealthy individuals, digital taxation, taxation of cross-border transactions, combating tax-related illicit financial flows, and using tax to address environmental challenges.

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EU Carbon Tax Creates Challenges for Some Developing Economies

  • By George Riddell
  • By Richard Albert

EY authors discuss the implications of EU’s new carbon tax that may significantly impact developing economies.

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EU Countries Coordinated but Not United in U.N. Discussions

  • By Elodie Lamer and Sarah Paez

EU member states have presented a common approach to discussions about a U.N. framework convention on international tax cooperation, but several countries are still not ready to discuss proposals.

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Treasury, Business Push Back on Australia Software-Tax Ruling

  • By Michael Rapoport

The US Treasury Department and business groups are at odds with Australia over its taxation of software — and that could prompt higher taxes, higher prices, and maybe even a rethink by US companies over how they’ll do business there.

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Vietnam’s Corporate Incentives to Offset Minimum Tax Too Limited

  • By Natasha Teja

Business groups are critical of Vietnam’s financial support plan to soften the impact of the global minimum tax on multinationals, saying it’s too vague and narrow in scope, with only large projects able to meet its eligibility conditions.

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The Senate Intensifies Its Focus on Offshoring

  • By Nana Ama Sarfo

Nana Ama Sarfo outlines some of the discussions at a recent Senate Budget Committee hearing on offshore tax avoidance.

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Ireland Forecasts Surplus Rise on Record Corporation Taxes

  • By Olivia Fletcher

Ireland has forecast a budget surplus of €8.6 billion ($9.2 billion) this year, citing anticipated record corporation tax receipts in a boost for the country that is in the process of setting up its sovereign wealth fund.

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Gain and Little Pain From New Bermuda Corporate Tax

  • By Martin A. Sullivan

Martin A. Sullivan examines the generous provisions of Bermuda’s new corporate income tax and how they interact with the OECD’s pillar 2 rules.

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EU Open to More Tax Transparency Measures Under Pillar 2

  • By Sarah Paez

The European Commission is still open to the possibility of proposing mandatory publication of the effective tax rates of large corporations operating in the EU, according to a top EU tax official.

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The New U.N. Framework Convention: Plurilateralism Could Be a Key to Success

  • By Peter Hongler and Simon Habich

Peter Hongler and Simon Habich explain that upcoming U.N. negotiations should look to establish the institutional groundwork for a more credible evolution of the international tax system, recognizing that a global consensus may not be imperative across all tax-related domains, and instead should strive for global inclusivity.

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Sweden Proposes Tax Breaks to Boost Economic Competitiveness

  • By Jan Stojaspal

Sweden’s finance ministry is aiming to pass a suite of tax breaks to enhance the country’s competitiveness and to support business and individuals who continue to struggle economically.

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Pace on U.N. Convention Is Rushing Consensus, EU Official Warns

  • By Elodie Lamer

Building consensus takes time, so the quick pace of the U.N.’s work on the terms of reference for a new framework convention on international tax cooperation is worrisome, a top EU tax official said.

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Singapore Refundable Investment Credit Aims to Attract Investors

  • By Sivakumar Saravan

While implementing a minimum effective tax rate of 15% under the OECD’s Pillar Two initiative, Singapore looks to stay competitive to businesses by granting credits to offset corporate income tax payable by companies with qualifying expenditures for approved projects.

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EU Report Calls for Circumvention of Unanimity Rule for Taxation

  • By Elodie Lamer

A report commissioned by EU leaders on the future of the single market calls for a harmonized tax framework and says allowing exceptions to the unanimity rule could take a bite out of tax avoidance.

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EU Backs Competitiveness Report Endorsing Investor Tax Breaks

  • By James Munson
  • By Stephen Gardner

EU leaders have broadly backed a roadmap for improving the bloc’s competitiveness, a blueprint that includes using tax incentives to meet its objectives.

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Unratified Global Tax Treaty Would Spark Digital Tax ‘Tsunami’

  • By Stephen Gardner

Ratification of an international treaty that would reallocate taxing rights over the profits of the world’s largest companies is “not the most likely scenario” despite its possibly being ready for signing in June, a former OECD tax chief said.

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Taxing the Super-Rich Is Brazil’s G-20 Plan for Climate, Hunger

  • By Maria Eloisa Capurro
  • By Andrew Rosati

As president of this year’s Group of 20 nations, Brazil is prioritizing implementation of a global minimum wealth tax on billionaires as a means to fund efforts to combat rising temperatures and poverty in low and middle-income countries.

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Automation Complicates Interpretation of EU Fixed Establishment Rule

  • By Stephen Gardner

An EU value-added tax exemption for companies’ foreign operations that aren’t considered “fixed establishments” may need to be redefined in the context of increased automation.

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Group Says UN Model Tax Treaty Change Would Spur Double Taxation

  • By Michael Rapoport

A proposed change to a United Nations model tax treaty is being debated for its potential for double taxation and increased compliance burdens for companies, while it is intended to expand the use of gross taxation to more kinds of cross-border business services and eliminate physical presence tests.

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EU Leaders Brace for Tough Talks on Competitiveness, Tax Law

  • By Elodie Lamer

EU heads of state are scheduled to discuss how to strengthen the bloc’s single market and competitiveness, and some member states are determined to debate even the most politically sensitive proposals, with potential tax implications.

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G-24 Countries Urge Multilateral Solution for Tax Issues

  • By Sarah Paez

G-24 countries are hoping to engage multilaterally on a range of tax issues, including corporate income tax and consumption tax, and shore up domestic revenue amid debt woes.

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Google, Meta to Face Tax in Canada in 2024 Despite US Complaints

  • By Brian Platt

Canada will start applying a proposed 3% tax on the world’s biggest technology companies this year, despite threats from American lawmakers to carry out trade reprisals against a levy that will primarily hit US firms.

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Do More on Tax to Boost Single Market, EU Report Tells Countries

  • By Stephen Gardner

 Former Italian prime minister Enrico Letta said European Union countries should better harmonize their tax systems as part of a major effort to boost the bloc’s single market.

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EU Looks to Streamline Reporting in Light of Minimum Tax

  • By Stephen Gardner

The European Union may have the opportunity to amend anti-tax avoidance rules and develop a new tax information exchange rule so that companies don’t have to report multiple times in different EU countries for minimum tax compliance purposes.

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