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OECD Pillars: A Bretton Woods Moment?

  • By Mindy Herzfeld

Mindy Herzfeld likens the OECD two-pillar proposals to various developments over the last century, including the Brettonwoods Agreement,which shaped the economic institutions that formed the basis for global economic relationships.

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BEPS 5 Years Later: Action 1 and the Quest to Tax Digital Activity

  • By Stephanie Soong Johnston

Countries hoped the base erosion and profit-shifting projectwould carve a path for taxing digital activity. But five years later, it's still not clear if that pathwill lead to a new paradigm or chaos.

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OECD Aims to Have Pandemic-Related Transfer Guidance Before 2021

  • By Ryan Finley

TheOECDplans to release practical guidance this year addressing some of the issues that participants in a recent consultation have identified as the most pressing transfer pricing challenges caused by the COVID-19 pandemic.

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EU Leaders to Discuss Digital Taxation in March

  • By Elodie Lamer

European CouncilPresidentCharles Michelhas informed EU leaders that hewill organize a summit on digital issues, including digital taxation, on March 25 and 26.

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Spanish Senate to Vote on Digital Services and Stock Sale Taxes

  • By William Hoke

The Finance Committee of theSpanish Senateon October 1 approved legislation to implement a digital services tax and a financial transaction tax.

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EU Solution Would Replace National Digital Taxes, Gentiloni Says

  • By Sarah Paez

In the event that OECD-level negotiations do not yield an agreement on digital taxation, any European proposalwould supersede member states' individual digital services taxes, according to theEU's top tax official.

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OECD Still Hopes for Global Tax Accord Despite Difficulties

  • By Stephanie Soong Johnston

Although it has been difficult to get countries moving toward a common approach to modernize global corporate tax rules, theOECDremains hopeful that consensus iswithin reach, the organization's tax boss said.

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EU Wants to Rate Tax Behavior of Tech Giants

  • By Elodie Lamer

TheEUis finalizing tougher rules to regulate big tech companies,with possible soft law measures to influence their tax behavior.

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OECD to Soon Consult on Global Tax Overhaul Blueprints

  • By Stephanie Soong Johnston

The OECDwill publish final blueprints and an impact assessment related to a proposal for modernizing global tax rules on October 12 andwill start a public consultation shortly thereafter, the OECD's tax chief said.

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Vodafone wins long-running $3bn India tax battle

  • By Nic Fildes and Stephanie Findlay

Vodafone haswon a long-running disputewith the Indian tax authoritieswhich argued that the UK telecoms group should pay almost ÔøΩ3bn in back taxes and penalties related to its 2007 acquisition of a local operator.

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Brussels to appeal against court decision quashing Apple tax order

  • By Javier Espinoza and Arthur Beesley

Margrethe Vestager, the EU's executive vice-president in charge of competition policy, said on Friday that Brusselswill appeal against a court decision that quashed an order for Apple to pay back ÔøΩ14.3bn in tax advantages to Ireland.

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INSIGHT: The OECDs Two Tax Pillars on DigitalizationA Multilateral Project in Search of a Shared Purpose

  • By Jefferson Vanderwolk

The Organization for Economic Cooperation and Development is expected next month to officially release its draft "blueprints" for Pillars 1 and 2 of the multilateral program for the digital economy. Jeff VanderWolk of Squire Patton Boggs sees a projectwhere the 137 participantswith differing views fall roughly into three camps, all lacking a shared purpose.

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EU Plans Digital Tax at Year-End Should OECD Talks Fail: Breton

  • By Tara Patel

The European Unionwill propose a digital tax on tech companies at the end of the year if nations fail to get a multilateral dealwithin the OECD, EU Commissioner Thierry Breton said Friday in an interview on BFM Business.

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Digital Tax Plan Has Pitfalls for Developing Countries: UN Group

  • By Isabel Gottlieb

The OECD's digital tax overhaul carries "potentially adverse implications" for developing countries,warned a new report from a panel convened by the United Nations. The time frame of the negotiations has been dictated by richer countries, and may be too fast for developing countries,which have fewer resources to devote to the process, the interim report said Thursday. Nearly 140 countries are negotiating a global tax overhaul at the Organization for Economic Cooperation and Development to address concerns about how tech giants and other multinationals are taxed.

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EU Aims to Ease Relief From Cross-Border Taxes on Dividends

  • By Stephen Gardner

The European Commission plans to propose streamlining systemswithin the European Union for claiming relief from double taxation of dividends. Proposals,whichwould be published by the end of 2022,would seek to improve on the current situation of "divergent, burdensome, lengthy and fraud-prone refund procedures for taxwithheld in cases of cross-border investment," the commission, the EU's executive, said in an action plan published Thursday.

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Apples $15 Billion Tax Victory Faces EU Appeal at Top Court (2)

  • By Aoife White and Stephanie Bodoni

Apple Inc.'s victory over a record back-tax order faces a challenge at the European Union's top court as Competition Commissioner Margrethe Vestager seeks to rescue her crackdown on allegedly unfair fiscal deals doled out to multinational companies. The EU's General Court "made a number of errors of law"when it sidedwith Apple in its ruling in July, the European Commission said in a statement on Friday announcing that itwould appeal to the EU Court of Justice.

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Companies Brace for Higher Taxes After U.S. Election

  • By Mark Maurer and Kristin Broughton

Finance executives at major U.S. companies expect corporate tax rates to rise following the presidential election in NovemberÔøΩno matterwhowins.

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Apple Court Triumph Forces Tough Choice for EUs Tax Crusade (2)

  • By Aoife White and Stephanie Bodoni

Apple Inc.'s July court triumph over a massive European Union back- tax order is forcing antitrust chief Margrethe Vestager to make a tough choice: Challenge a ruling that faulted the EU investigation or accept judges' criticisms and re-examine a case started more than six years ago.

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Exempting GILTI from OECD Global Tax Rate Raises More Questions

  • By Hamza Ali and Isabell Gottlieb

U.S. multinationals'wish to be excluded from an OECD-led effort to set a global minimum tax rate could comewith new administrative burdens. The nearly 140 countries negotiating a global tax overhaul at the Organization for Economic Cooperation and Development are consideringwhether to allow U.S. companies a pass on global minimum tax rules, because they're already subject to a similar regime in the U.S.

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TAXUD Director Defends OECD Talks on Digital Tax

  • By Elodie Lamer

An officialwith theEuropean Commission's Directorate-General forTaxation and Customs Union(DGTAXUD) said observers shouldn't assume a new U.S. administrationwill be more flexible regarding international negotiations on digital taxation.

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EU Council Presidency Supports Decision on Public CbC Reporting

  • By Sarah Paez

The GermanEU Councilpresidencywill support a decision on public country-by-country reporting and says a majority of member states appear to support it.

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Bidens Onshoring Incentives in a World Without Work

  • By Mindy Herzfeld

Mindy Herzfeld describes proposals from Democratic presidential candidate Joe Biden to encourage companies to move jobs back to the United States and discourage moving jobs offshore.

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OECD Agreement on Digital Taxation at Top of Ubers Wish List

  • By Stephanie Soong Johnston

Ubersupports the OECD-ledwork on a potential global corporate tax overhaul for the digital age and continues to hope for multilateral agreement on that proposal, the company's tax chief said.

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EU Will Act Unilaterally if OECD Tax Deal Doesnt Yield Fairness

  • By Sarah Paez

The EU "will spare no effort to reach agreement" on digital taxation in theOECD/G-20inclusive framework, but itwill take unilateral measures if necessary,European CommissionPresidentUrsula von der Leyensaid.

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Brazil Transfer Pricing Reform Key for Adopting Digital Tax Plan

  • By Stephanie Soong Johnston

Brazilwill need to align its transfer pricing system more closelywith the arm's-length standard if itwants to implement a proposed global approach to tax the digital economy, a topOECDofficial said.

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Dutch Tax Plan Scraps Rate Cut for Multinationals

  • By Sarah Paez

The Netherlands is canceling its top corporate tax rate cut and plans to offer other relief measures, including employment and investment tax credits,while introducing a carbon tax, according to the government's 2021 tax plan.

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Agreement on Pillar 1 Unlikely in October, Saint-Amans Says

  • By Elodie Lamer

The head of theOECD Centre for Tax Policy and Administrationfears that negotiations on pillar 1 of the multilateral solution to taxing the digital economywill take too long and countrieswill move unilaterally.

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United Kingdom Mulling Capital Investment Tax Break, Report Says

  • By Stephanie Soong Johnston

As part of a broader response to the COVID-19 pandemic's economic fallout, the U.K. government is reportedly considering giving companies a full tax break in a bid to boost investment in plant and machinery.

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Most EU Member States Take Wait and See Approach to Digital Tax

  • By Elodie Lamer

Most EU member states don'twant to rush a digital tax because the U.S. stance might change after the presidential election, sources said after a meeting of theEconomic and Financial Affairs CouncilSeptember 12.

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New Zealands Labour Party to Levy a DST if OECD Talks Fail

  • By William Hoke

New Zealand'sLabour Partymade headlines recently in announcing plans to increase taxes for high earners, but the party also said itwill move quickly to implement a digital servicestax ifOECDnegotiations fail.

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Biden Takes Aim at Offshoring With Proposed Tax Hike

  • By Alexis Gravely

A new tax penalty for corporations intended to curb overseas manufacturing has been added to the campaign platform of Democratic presidential candidateJoe Biden.

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U.S. Clearly Doesnt Want Digital Tax Deal, French Minister Says

  • By Stephanie Soong Johnston

The United States is obstructingOECD-led negotiations on a global corporate tax overhaul proposal, so theEUshould prepare its own digital taxation plan now in case talks fail, a top French minister reportedly said.

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Proposed NOL Regs Contravene Rules for Dual Residents

  • By Emily L. Foster

Multinational companieswarn that the proposed consolidated net operating loss regulationswould undermine the policies for limiting the use of losses incurred by corporations that are residents in the United States and a foreign jurisdiction.

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The Trump Treasury Redefines Inappropriate Tax Planning

  • By Mindy Herzfeld

Mindy Herzfeld sheds light on Treasury's interpretation of the international tax provisions of the Tax Cuts and Jobs Act, often inways not supported by legislative history or other proposals that led to the act's creation and passage.

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Facebook Wont Pass on U.K. Digital Tax Costs for Now

  • By Stephanie Soong Johnston

Social media giant Facebook does not intend to pass along the costs of the U.K. digital services tax to its U.K advertising customers, at least for now, a company spokesperson said.

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Draft U.N. Article to Tax Digital Services May See Wide Adoption

  • By Stephanie Soong Johnston

If a new draft article to tax digital services is added to the U.N. model tax convention, it's likely itwill then be included in several existing and future tax treaties, an Indian official said.

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Facebook France to Pay $106 Million in Back Taxes

  • By Sarah Paez

Facebook's French subsidiary has agreed to pay over ÔøΩ100 million in back taxes to French tax authorities after an audit found the company had not paid the correct amount of taxes for nearly a decade.

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U.K. Denies Government U-Turn on Digital Services Tax

  • By Stephanie Soong Johnston

HM Treasuryhas denied a U.K. media report that the U.K. government is considering abolishing the digital services tax, partly because of U.K.-U.S. trade concerns as both countries continue negotiating a deal.

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Economic Analysis: New Data Show So Far No Post-TCJA Profit Shifting to U.S.

  • By Martin A. Sullivan

In economic analysis, Martin A. Sullivan says that new data show little change in profit shifting by multinational corporations since enactment of the Tax Cuts and Jobs Act, but that it's still early.

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Final DRD Regs Follow Through on Promise to Limit Deduction

  • By Andrew Velarde
  • By Annagabriella Colon

TheIRSandTreasuryhave released final regs on thedividends received deduction(DRD), refusing to blink in the face of charges from taxpayers and practitioners that the rules go beyond their authority.

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The GILTI High-Tax Exception: Who Benefits?

  • By Mindy Herzfeld

Mindy Herzfeld examineswhether, in finalizing regulations implementing the subpart F high-tax exception to items of income thatwould otherwise be tested income taxable as global intangible low-taxed income, Treasury exceeded its statutory authority, subverted congressional intent, and provided a giveaway to corporate taxpayers.

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Why the United Nations Digital Tax Proposal Deserves More Attention

  • By Nana Ama Sarfo

Nana Ama Sarfo looks at the U.N.'s new digital services treaty proposal, how it serves the interests of developing countries, and how it diverges from the OECD's approach.

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Dutch Exit Tax Gains Support but Could Threaten Business Climate

  • By Sarah Paez

A Dutch bill thatwould impose a conditional exit tax on reorganizations like company transfers and mergers may face legal troubles and have unintended consequences for the business climate.

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MasterCard Escapes Equalization Levy for Now, India Court Says

  • By Stephanie Soong Johnston

MasterCardwon't have to pay an equalization levy in India because it already has a permanent establishment there, but its liability may change depending on the outcome of its appeal in a separate court case.

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Top Brazilian Lawmaker Pans Digital Financial Transactions Tax

  • By William Hoke

The speaker of Brazil'sChamber of Deputiesvoiced opposition to the government's plans for a "digital" tax on financial transactions because of its potential similarity to a lapsed financial transactions tax thatwaswidely criticized.

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OECD Pillar 2 Draft Further Maps Out GLOBE Minimum Tax Proposal

  • By Stephanie Soong Johnston and Ryan Finley

AnOECDdraft report on its global anti-base-erosion (GLOBE) proposal charts out significant design progress but has yet to address how itwill coexistwith the U.S. global intangible low-taxed income provision.

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Taxing the Digital Economy: Options, Trade Considerations, and a Solution

  • By John N. Bush and Rachel Thrasher

In this article, the authors consider four options for taxing the digital economy ÔøΩ tariffs on electronic commerce, VAT, the corporate income tax, and digital services taxes. They examine the potential effects of trade laws on each and propose a solution thatwould allow countries to select a tax that is suited to their needs.

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A New Corporate Tax (1)

  • By Reuven S. Avi-Yonah

In this article, the author argues for the development of a new corporate tax thatwould limit the power and regulate the behavior of our largest corporations,which are monopolies or quasi-monopolies that dominate their fields and drive competitors out of business.

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Brazils Push for a Proper VAT

  • By Robert Goulder

Robert Goulder examines Brazil's efforts to replace their fragmented consumption tax structurewith a simplified federal VAT.

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Potential $11 Billion in Tax Threatens Unilever Restructuring

  • By Amanda Athanasiou

A proposed Dutch exit tax on expatriating entities is throwing awrench in the latest attempt byAnglo-Dutch consumer products companyUnileverto simplify its dual-entity structure.

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