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Global Minimum Tax Deal Advances With Partial Reprieve for U.S.-Based Companies

  • By Richard Rubin

On February 2, 2023, the Organisation for Economic Co-operation and Development (OECD) described how the U.S. tax system will interact with the minimum taxes being implemented in other countries. These rules provide U.S. companies with a partial reprieve through 2025. This new guidance spelled out how the existing 10.5% minimum tax on U.S. companies' foreign income interacts with other countries' new taxes. However, other countries will only be so tolerant of the U.S.'s delayed implementation. In addition, U.S. lawmakers are increasingly hesitant about a coordinated global corporate tax increase because of the possibility that such an increase will primarily affect U.S. companies. The United States will need to figure out what can be done to alleviate these concerns before 2025.

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EU Prepares to Offer Clean Tech Tax Breaks to Compete With U.S. Green Subsidy Push

  • By Kim Mackrael

The Inflation Reduction Act, signed into law in August 2022, provided tax credits and other support for clean-energy projects. Concerned that these subsidies will draw investment away from Europe, the European Union (EU) wants to provide tax breaks and other aid to clean-tech companies. The EU's proposed response said that state-aid rules could be loosened to make it easier for governments to back new investment in clean-tech production facilities, including through tax breaks.

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Pillar 2, Fiat, and the EU Unanimity Rule on Tax Matters

  • By Sarah Paez

This Editorial considers the current approach of keeping the unanimity rule for the making of tax legislation in Europe, while at the same time consistently exploring alternative pathways to circumvent it. It argues that this approach is a reflection of the trade-off between (perceived) national tax sovereignty on one hand, and tax efficiency and fairness on the other hand.

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State Strategic Responses to the GloBE Rules

  • By Heydon Wardell-Burrus

The article analyzes strategies that low-income countries and high-income countries might undertake in response to the GloBE rules on the assumption that are indeed implemented by a critical mass of countries.

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A Theory of Global Tax Hubs

  • By Eduardo A. Baistrocchi

Baistrocchi explores Global tax hubs which he describes as the black boxes of the international tax regime. The paper offers the theory of global tax hubs as an intermediation market. It argues that tax hubs are the matchmakers of the international tax regime.

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Digitalization and Cross-Border Tax Fraud: Evidence from E-Invoicing in Italy

  • By Marwin Heinemann and Wojciech Stiller

Heinemann and Stiller analyze the impact of the widely introduced e-invoicing in Italy on cross-border value-added tax fraud. They calculate trade gaps based on product flows on the most detailed level between Italy and the remaining countries of the European Union with results suggesting a significant decline in cross-border fraud in response to the introduction of mandatory e-invoicing, providing an important rationale for the application of this measure by other countries.

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Introducing a Global Minimum Tax (Pillar Two) in Canada: Some Knowns and Unknowns

  • By Jinyan Li

This paper provides a high-level overview of Pillar Two Global Minimum Tax in terms of its policy objectives, technical design and implications for Canada. After teasing out some significant known and unknown challenges, it offers some thoughts on whether, and if so, how and when Canada can proceed with implementation.

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Access to Tax Treaty Dispute Resolution Mechanisms in Cases of Abuse

  • By Aitor Navarro

Navarro’s paper is aimed at depicting the rather asymmetrical state of affairs on the access to dispute resolution remedies in instances of tax abuse. It also purports to demonstrate that there are compelling policy reasons to support granting access to both mutual agreement and arbitration procedures in these cases and to criticize the incoherencies that originate from the existing restrictions.

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E.U. Delays Digital Levy as Tax Talks Proceed

  • By Alan Rappeport

BRUSSELS - The United States secured a diplomatic victory in Europewhen European Union officials agreed to postpone their proposal for a digital levy that threatened to derail a global effort to crack down on tax havens. The delay removes another potential obstacle to the broader tax agreement,which gained momentum over theweekend after finance ministers from the Group of 20 countries formally backed a new framework. That deal,which officials hope to make final by October,would usher in a global minimum tax of at least 15 percent and allow countries to tax large, profitable companies based onwhere their goods and services are sold. If enacted, the changeswould entail the biggest overhaul of the international tax system in a century.

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Pushing Pillar 1 Past Congress

  • By Mindy Herzfeld

The article discusses strategies the Biden administration may be considering to get Pillar 1 through Congress in away thatwould not require a 2/3 Senate vote, aswould be required for a tax treaty.

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OECD Tax Chief Outlines Next Steps for Global Tax Reform Deal

  • By Stephanie Soong Johnston

The OECD aims to complete a multilateral convention and model legislation by the end of 2021 or early 2022 so countries can start implementing new rules under a two-pillar global tax reform deal in 2023. During a July 16 OECD podcast, Pascal Saint-Amans, director of the OECD's Centre for Tax Policy and Administration, discussed translating the political agreement that more than 130 countries struck in recentweeks into concrete implementation. "The next step is finalizing the political deal in October. There is not much to do, just a few numbers to firm up," Saint-Amans said. "The following stepwill be the implementation to move from a political agreement to legislation."

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Amount A Plan Is a Formulary Approach Test, OECD Official Says

  • By Andrew Velarde

A key part of a G-20-backed tax reform planwill be a test ofwhether a formulary approach can be used morewidelywhen it comes to multinational profit allocation, a top OECD official said. Grace Perez-Navarro, the OECD's deputy tax chief, highlighted elements of a two-pillar global tax overhaul plan that more than 130 countries had agreed on and G-20 finance ministers recently approved. "This major achievement has been a long time coming," she said July 13 during awebcast organized by the Urban-Brookings Tax Policy Center.

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Developing Countries Need Political Presence at OECD Tax Talks

  • By Sarah Paez

Developing countries must mobilize political power to ensure fair representation in the OECD inclusive framework on base erosion and profit shifting, according to Loganwort, executive director of the African Tax Administration Forum. During a July 9 Tax Justice Network virtual conference, panelists representing the interests of developing countries said they felt that those countrieswere sidelined during OECD negotiations on a two-pillar solution to modernize global corporate tax rules because of a lack of political representation. At a June 30 meeting, 130 of the 139 countries in the OECD inclusive framework on BEPS released a statement agreeing to a two-pillar plan thatwould revise profit allocation rules and tentatively set a global minimum corporate tax rate of 15 percent.

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Pillar 1 of Global Tax Deal on a Slower U.S. Track, Yellen Says

  • By Stephanie Soong Johnston

The U.S. governmentwill decidewhat's necessary to push new profit allocation rules through the Senate as part of a G-20-backed global tax reform deal once an implementation plan is finalized, perhaps in early 2022. U.S. Treasury Secretary Janet Yellen confirmed July 11 that Treasury is pushing to include measures to implement pillar 2,which calls for global minimum taxation, of the two-pillar plan in a forthcoming budget resolution and reconciliation package. Shewas speaking during a press conference the day after G-20 finance ministers and central bank governors concluded their July 9-10 meeting in Venice, Italy, under the Italian presidency,where ministers endorsed the plan.

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Amazon Announces New Ad Fees in Countries With DSTs

  • By Stephanie Soong Johnston

Amazon has notified advertisers that itwill soon apply new fees to their invoices if their ads are served in six countrieswith digital services taxes, including the United Kingdom and France. The company confirmed the change in a July 16 email to Amazon Advertising clients, saying that new "regulatory advertising fees"would start applying September 1. According to a company help page, the new feeswill be included on invoices "when an ad is served in and/orwhen ads are purchased by advertisers in certain countries."

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European Parliament Members Push Back Against Digital Levy Delay

  • By Jean Comte

Prominent members of the European Parliament have asked the European Commission not to postpone its digital tax proposal. The commission said on July 12 that it had put on hold itswork on a digital levy proposal in order not to impede the OECD-led negotiations on global tax reforms. The movewaswelcomed by the OECD but criticized by the EP,which had obtained in November 2020 a commitment from the commission to propose a digital levy by June 2021. The commitment, crystallized in an interinstitutional agreement, aimed to secure the reimbursement of the EU's ÔøΩ750 billion coronavirus recovery plan.

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EU Digital Levy Delay Is Welcome News, OECD Deputy Chief Says

  • By Stephanie Soong Johnston

The European Commission's decision to postpone its digital levy proposal is a positive development andwill allow countries to finalize the details of a two-pillar global tax reform agreement, according to a top OECD official. "In the end, everyonewill have to play his or her part in the sense that no countrywill do something thatwill be inconsistentwith this global dealwhen it's done," OECD Deputy Secretary-General Masamichi Kono said July 14 during awebcast organized by the Atlantic Council Geoeconomics Center.

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US Treasury secretary charms EU officials in Brussels

  • By Hannah Brenton

U.S. economy chief Janet Yellen had successfully stalled EU plans for a digital levy and told national governments how to run their economies. Yet EU officials had nothing but effusive praise for their American visitor. "We could say that in terms of our relationshipswith the U.S.we have gone from awinter of discontent to a summer of cooperation," Economy Commissioner Paolo Gentiloni told journalists. The European Commission confirmed itwould bow to U.S. demands to put its plans on hold until the fall.

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International Tax Law and its Influence on National Tax Systems

  • By Craig Elliffe

In this paper it is controversially suggested that international tax law is broader than the traditional view of most academics. In addition to domestic laws that cover cross-border transactions and double taxation agreements (or their multilateral counterparts) there is a special consensus international tax law (CITL) based on the institutions, instruments and interpretation implemented by international consensus. This paper exploreswhat is meant by international tax law. Theweight of opinion does not support the view that CIL presently creates any binding tax obligations on States. This paper proposes that there is, however, an emerging system based on common understandings,with the legal duties of cooperation and underpinning expectations of implementationwhich should be recognized as creating obligations upon States even though it does not constitute CIL.

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Global Tax Deal Marks Big Advance for Cooperation, but Tougher Tasks Lie Ahead

  • By Paul Hannon and Giovanni Legorano

Finance chiefs from the Group of 20 leading economies endorsed an overhaul of the rules for taxing international companies, a landmark achievement of global cooperation after years of tensions. G-20 members have rarely been able to agree to such ambitious changes over the past decade of disputes over trade, investment and jobs, although they didwork together to offset the economic impact of the Covid-19 pandemic. The tax agreement, negotiated earlier this month by 130 countries, has raised hopes that major economies can find common approaches to tackling other global problems, such as climate change and trade.

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G-20 finance ministers back global tax overhaul

  • By Naomi Jagoda

Finance officials in the Group of 20 (G-20) endorsed "key components" of a framework for an international tax overhaul that is a top priority of the Biden administration. The G-20 finance ministers and central bank governors announced their backing of major elements of the Organization for Economic Cooperation and Development's (OECD) tax framework following a meeting in Venice, Italy. The framework calls for a global minimum tax for corporations of at least 15 percent.

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EU Delays Push for Digital Levy to Focus on Global Tax Deal (4)

  • By Aoife White

The European Union said that itwould postpone its push for a controversial digital levy to focus on a negotiation over a broader minimum global tax deal struck by theworld's largest economies. The U.S. has lobbied against the levy on digital sales thatwas likely to hit Silicon Valley giants' business in Europe. The EU had pledged to introduce a levy if therewas no progress on a sweeping effort to tax corporations more uniformly. Such a pact now seems more likely after the Group of 20 endorsed the principles of a global-tax agreement.

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Yellen to Press Europe on Digital Tax Plan Following G-20 Accord

  • By William Horobin

U.S. Treasury Secretary Janet Yellenwill press European Union officials in Brussels to reconsider their plan to propose a digital levy after securing the Group of Twenty's endorsement for the principles of a global corporate-tax agreement. Yellen is in Brussels following the gathering of G-20 finance ministers and central bankers in Venice,which concludedwith the group's call to finishwork on the global plan's details by October.

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Big Countries Using Tax Talks to Get More Revenue, Varadkar Says

  • By Peter Flanagan

Bigger countries are using negotiations on global corporation tax reform to increase their own tax revenue at the expense of smaller nations, Ireland's deputy prime minister said. "This isn't just about tax justice and big companies paying their fair share," Leo Varadkar told reporters in Dublin. "This is also about big countries trying to get a bigger share of the pie."

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Pillar Ones Reallocation of Taxing Rights: Has Anyone Consulted the U.S. Trade Representative?

  • By Jefferson Vanderwolk

On July 1, 2021, the OECD-led Inclusive Framework on BEPS announced that 130 countries had agreed on revised outlines of a two-pillar plan calling in part for a reallocation of taxing rights regarding certain large multinational businesses. The author discusses the proposed reallocation in light of the U.S. Trade Representative's recent reports on digital services taxes.

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Label Global Tax Rate Rebels as Harmful, EU Lawmakers Urge (2)

  • By Stephen Gardner

An influential EU panel has suggested using a mechanism designed to combat harmful tax practices to push EU member states into accepting a global minimum tax rate. Over 130 countries have agreed on a global minimum tax rate of "at least 15%" but four EU countriesÔøΩCyprus, Estonia, Hungary, and IrelandÔøΩhave not signed up to the agreement,whichwas negotiated through the Organization for Economic Cooperation and Development.

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Global Tax Deal Heads Down Perilous Path in Congress

  • By Richard Rubin

A complex international corporate tax deal that took years to hammer out soon faces one of its toughest tests: the U.S. Congress.The Group of 20 major economies backed the plan in Venice, Italy, following the earlier endorsement from a broader 130-country group. The plan, aimed at limiting corporate tax avoidance,would revamp longstanding international rules and is crucial to President Biden's plans to raise corporate taxes."Theworld is ready to end the global race to the bottom on corporate taxation, and there's broad consensus about how to do it," Treasury Secretary Janet Yellen said.

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Global Minimum Tax Deal Marked a Win for Yellen. Now She Must Sell It to Congress.

  • By Kate Davidson

When the U.S. secured international backing for a global minimum corporate tax, it marked an early victory for Treasury Secretary Janet Yellen as the country's top financial diplomat and paved theway for a key plank of President Biden's domestic agenda. People involved in the negotiations credit Ms. Yellenwith reviving yearslong talks to clamp down on tax avoidance by multinational firms. The breakthrough potentially set the stage for the most sweeping change in international taxation in a century.

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EU and U.S. to Discuss Digital Tax Ahead of Blocs Levy Plan (1)

  • By Aoife White

The European Union's digital chiefwill meet U.S. Treasury Secretary Janet Yellen as the EU delayed plans for a digital levy after a potential global tax breakthrough. Margrethe Vestager, the EU's executive vice-president for digital issues, is now due to propose a new EU tax on technology companies' revenues on July 20, aweek later than planned, according to a document seen by Bloomberg News.

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U.S. Trade Chief Asks Canada to Abandon Proposed Digital Tax

  • By Eric Martin

In a meetingwith Mary Ng, Canada's trade minister, U.S. Trade Representative Katherine Tai urged Canada to abandon its proposed unilateral digital-service tax.

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Global Tax Deal Will Survive Europe Digital-Tax Plan, OECD Says

  • By William Horobin and Maria Tadeo

The European Union's plan to propose a new digital-services tax is unlikely to undermine global talks aimed at eliminating such levies, according to the head of the international group spearheading the discussions. "I know for a fact that the European Union is very conscious of the importance of this deal on international tax reform," Mathias Cormann, secretary-general of the Organization for Economic Cooperation and Development, said in a Bloomberg Television interview.

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France Sees Tax Deal Near, Pushes for Minimum Rate Above 15%

  • By William Horobin and Maria Tadeo

William Horobin and Maria Tadeo

French Finance Minister Bruno Le Maire said he is confident the Group of 20 economieswill back a deal on international tax, even as his country pushes for a higher minimum corporate rate. The G-20 meeting in Venice is poised to give its backing to a deal signed by 131 countries for a minimum corporate levy of "at least 15%," and new rules for dividing up the tax revenues from theworld's largest companies -- particularly U.S. tech giants.

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Spains Calvino: Confident There Will Be A Deal on Digital Tax

  • By Alessandra Migliaccio and Maria Tadeo

"I hope and look forward to Ireland joining this consensus sowe can have a fairer system," Spanish Economy Minister Nadia Calvino says in interview during G20 in Venice, Italy.

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G-20 Finance Chiefs Vow to Overcome Tax Deal Hurdles by October

  • By Birgit Jennen and Christopher Condon

Top officials from the U.S., Germany and France each expressed confidence that a proposed global tax deal can overcome political obstacles inwashington andwithin the European Union in time for it to be finalized in October. "There's morework to be done, but I'm really hopeful thatwith the growing consensuswe're on a path to a tax regime thatwill be fair for all of our citizens," U.S. Treasury Secretary Janet Yellen told reporters on the sidelines of a Group of 20 meeting of finance ministers and central bankers in Venice.

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Global Tax Overhaul Gains Steam as G20 Backs New Levies

  • By Alan Rappeport

Global leaders on Saturday agreed to move aheadwithwhatwould be the most significant overhaul of the international tax system in decades,with finance ministers from theworld's 20 largest economies backing a proposal thatwould crack down on tax havens and impose new levies on large, profitable multinational companies.

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Ireland Fights for Its Tax Breaks


Ireland stands to lose up to a quarter of its corporate tax haul, and at the G20 meeting itwill push for terms thatwould allow it and other small countries to make up for the loss.

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G20 ratchets up pressure on global corporate tax deal holdouts

  • By Miles Johnson

Theworld's largest economieswill thisweekend pile pressure on to holdout nationswhich are refusing to sign up to a global tax reform deal thatwould impose a minimum levy on multinational corporations.

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Brussels set to delay digital levy plan after G20 backs tax deal

  • By Sam Fleming and Javier Espinoza and Miles Johnson

Brussels is set to delay plans for its controversial digital levy until the autumn in an effort to boost the prospects of a global corporate tax reform deal.

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G20 ministers endorse carbon pricing to help tackle climate change

  • By Leslie Hook and Kristen Talman

G20 finance ministers have collectively endorsed carbon pricing for the first time, describing the once contentious idea as one of "awide set of tools" to tackle climate change.

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Brady Skeptical of Global Tax Deal Amid EU Digital Levy Push

  • By Stephanie Soong Johnston

The top House Republican taxwriter remains unconvinced that a global tax reform deal reachedwithin the OECD frameworkwill roll back digital services taxes, especially because the EU plans on introducing a digital levy anyway.

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Crapo and Brady Urge Yellen to Push for Immediate End to DSTs

  • By Stephanie Soong Johnston

Congresswon't support an OECD tax reform deal unless it protects the U.S. economy, including through the instant repeal of digital services taxes, top Republican taxwriterswarned Treasury ahead of a key G-20 meeting.

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European Countries With DSTs Linked to Weaker Trade Competitiveness

  • By Stephanie Soong Johnston

The five major pre-Brexit EU countrieswith digital services taxes have seen their trade competitiveness in digital services plummet over the years,which could explainwhy they decided to adopt those taxes, economists said.

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Is There Room for Compromise on GILTI?

  • By Mindy Herzfeld

Mindy Herzfeld looks at options for adjusting the much-maligned global intangible low-taxed income regime to further President Biden's plan to use corporate tax policy to improve fairness and equity in U.S. society.

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EU Opens Consultation on Debt-Equity Bias in Corporate Taxation

  • By Kiarra M. Strocko

The European Commission has launched a public consultation on a proposal for a directive thatwould mitigate tax-induced debt-equity bias by offering a tax allowance for companies that pursue equity financing.

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France Vows to Address U.S. Concerns Over Digital Levy

  • By Elodie Lamer

French Finance Minister Bruno Le Maire said July 6 that the EU's digital levy proposal is not "directed against the United States,"which fears that an EU tax could threaten progress at the OECD level.

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U.S. Reconciliation Bill May Have Global Minimum Tax Provisions

  • By Stephanie Soong Johnston

Treasury is in talkswith Congress's top Democratic taxwriters about including global minimum tax provisions in a partisan reconciliation package thatwould align the United States' domestic prioritieswith its OECD inclusive framework goals.

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G-20 Finance Ministers Greenlight Global Tax Reform Deal

  • By Stephanie Soong Johnston

The finance ministers of theworld's twenty largest economies have reached political agreement on a two-pillar global tax reform plan, calling on a small group of holdout countries to join in on the deal.

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Whats In a Name? EU Digital Levy Isnt a Tax, Vestager Says

  • By William Hoke

Shakespeare said a rose by any other namewould smell as sweet, but multinational companies aren't likely to draw the same conclusion about a claim that the EU's proposed digital levy is not a tax.

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Decoding the global tax deal

  • By Ryan Heath

Theworld's largest economies agreed Thursday to sweeping changes to the global tax system. They still have a lot ofwork to do on how to make that agreementwork in practice, and itwon't be operational until at least 2023.

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U.S. Proposal for 15% Global Minimum Tax Wins Support From 130 Countries


An effort to push the most sweeping changes to the global tax system in a century gained significant momentum on Thursdaywhen 130 nations agreed to a blueprint inwhich multinational corporationswould pay an appropriate share of taxwherever they operate.

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