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Int'l Tax News

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Amazon Seller Fees to Spike After U.K. DST Becomes Law

  • By Stephanie Soong Johnston

Vendors onAmazon'sU.K. sitewill have to pay an extra 2 percent in seller fees because of the controversial U.K. digital services tax, following similar increases in France and Italy.

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Reforming Digital Taxation Amid Antitrust, Trade, and Class Tensions

  • By Mindy Herzfeld

Mindy Herzfeld discusses digital economy taxation reformwithin the context of antitrust, trade, and class tensions.

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U.N. Committee Members Issue Independent Digital Taxation

  • By Ryan Finley

Agroup ofU.N.Tax Committee members from developing countries have proposed an approach to taxing digital services income that differs significantly from theOECD's pillar 1 proposal, including in its scope and allocation methods.

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OECD Draft Blueprint Mulls New Pillar 1 Multilateral Convention

  • By Stephanie Soong Johnston

Workwill proceed on the development of a new multilateral convention thatwould implement pillar 1 of a proposed global tax overhaul, according to a draft report from theOECD.

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New Detail on OECDs Pillar 1 Proposal Emerges in Draft Report

  • By Ryan Finley and Stephanie Soong Johnston

TheOECD's draft blueprint report on pillar 1 of its international corporate tax reform project reflects significant technical progress on revised nexus and profit allocation rules, but also acknowledges that important questions remain unresolved.

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Amazon Seller Fees to Spike After U.K. DST Becomes Law (1)

  • By Stephanie Soong Johnston

Vendors onAmazon'sU.K. sitewill have to pay an extra 2 percent in seller fees because of the controversial U.K. digital services tax, following similar increases in France and Italy.

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OECD To Consider Exemptions For New Tax System In Report

  • By Alex M. Parker

An international consortium of tax officials negotiating a new global taxing systemwill considerwhether to remove prescription drugs from the scope of taxation, aswell as an expanded list of exemptions.

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Dutch Exit Tax Discourages MNEs From Leaving

  • By Danish Mehboob¬†

The Netherlands is expanding its dividendwithholding tax (WHT) regime by adding an exit tax on companies such as Unilever that reorganize and move profit reserves to countries that do not impose Dutch dividendwHT.

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OECD and Brazil Seek Input on Possible Safe Harbor Approaches

  • By Ryan Finley

TheOECDand Brazilian tax administration have opened a consultation on the adoption of safe harbors in Brazil's transfer pricing regime, part of an effort to gradually align the country's unorthodox systemwith international norms.

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GILTI High-Tax Rules and Foreign Tax Credits

  • By Lee A. Sheppard

In news analysis, Lee A. Sheppard analyzes the recently released final regulations on global intangible low-taxed income, pointing out that they could pave theway for a per-country foreign tax credit limit for GILTI.

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U.S. FDII Regs Provide a Roadmap for Digital Taxation

  • By Mindy Herzfeld

Mindy Herzfeld outlines new rules released by the U.S. Treasury as part of the final section 250 regulations.

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Bill to Impose Digital Services Tax Sent to Spanish Senate

  • By William Hoke

Spain's Chamber of Deputieshas approved and sent to theSenatelegislation to enact a digital services tax and a financial transactions tax.

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Full Global Tax Reform Unlikely in 2020, Ex-OECD Tax Forum Head Says

  • By Stephanie Soong Johnston

The COVID-19 pandemic may have dimmed the prospects of full global tax reform by the end of 2020, but governmentswill miss a historic opportunity if talks break down, a former tax chief said.

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State Aid Disambiguation: What the Apple Decision Does Not Tell Us About BEPS

  • By Robert Goulder

Robert Goulder questions the linkage between the European Commission's state aid case against Apple and the OECD's project on the digital economy.

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Kenya's DST Could Force Out Digital Gaints

  • By Mattias Cruz Cano

Multinational enterprises (MNEs) that are struggling to decipher Kenya's vague digital services tax (DST) legislation may decide to exit the country instead of risking non-compliance

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Crunch Time: What the Apple Decision Means for Global Tax Reform

  • By Stephanie Soong Johnston

The core of the EUGeneral Court's recentAppledecision may be state aid, but it could raise stakes as countries aim for agreement on global corporate tax reform for the digital age.

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Philippine President Urges Congress to Cut Corporate Tax Rate

  • By William Hoke

PhilippinePresident Rodrigo Dutertehas called onCongressto pass legislation cutting the corporate income tax rate from 30 percent to 25 percent and extending the loss carryover period for most taxpayers to five years.

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Apple: Why the EU Needs a Common Corporate Income Tax

  • By Frans¬†Vanistendael

In this article, the author discusses theGeneral Court of the European Union's judgment in theApplestate aid case and its potential impact on how theEUaddresses state aid and tax abuse.

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Why Sweden Should Lobby for a Temporary OECD-Approved Digital Services Tax

  • By Torsten Fensby

In this article, the author argues that theOECD's two-pillar approach to digital taxationwould prove harmful to the Swedish economy and therefore the country should build support for an OECD-approved digital services tax thatwould sunset once an appropriate multilateral solution is developed.

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European Parliament to Renew Push for EU Taxes

  • By Jean Comte

Members of theEuropean Parliamentare threatening to reject the 2021-2027 EU budget if member states don't make a clear commitment to introducing new EU-wide taxes to finance it.

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Cost-Sharing Arrangements May Have Less Appeal Post-TCJA

  • By Ryan Finley

The Tax Cuts and Jobs Act's amendments to the definition of intangible property and codification of the aggregation and realistic alternative principles may discourage taxpayers' use of cost-sharing arrangements in the future.

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U.K. Digital Services Tax Becomes Law, Stoking Trade Tensions

  • By Stephanie Soong Johnston

The U.K digital services tax has become law, setting the stage for escalating tradewar tensions between the United Kingdom and the United States,which is investigatingwhether the tax discriminates against American business interests.

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OECD Sketches Out Progress on Global Tax Reform Blueprints

  • By Stephanie Soong Johnston

TheOECDhas made good progress on designing a global tax reform plan, but stakeholders may need to be realistic about the prospect of countries agreeing on that plan by year-end, officials said.

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The Trouble With Pillars in International Tax Policy

  • By Lucas De Lima Carvalho

In this article, the author discusses theOECD's two-pillar approach to taxing the digital economy. He focuses on the narrative of "pillar-building" in international tax policy and the difference between building consensus and manufacturing consent.

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Authority Questions Arise for FDII Heightened Substantiation

  • By Andrew Velarde

Treasury's decision to base its substantiation requirements for some foreign-derived intangible income transactions on those of two other tax code provisions may lead to taxpayers questioning the authority uponwhich it rests.

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BEPS Primer: Past, Present, and Future

  • By Jeffery M. Kadet

In this two-part article, the author updates his examination of the initialOECDbase erosion and profit-shifting project, and he considers the process and potential success of BEPS 2.0. This first installment examines the origin of the BEPS project, its objectives, and how it may proceed in the future. The second installmentwill focus on BEPS 2.0.

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EU Urges Blocking State Aid to Companies in Tax Havens

  • By Matt Thompson¬†

The European Commission recommended Tuesday that financial support for companies in the future be contingent on their not making use of countries on the European Union's so-called tax haven blacklist.

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OECD Tax Chief Fears Pillar Two Will Not Find Support Without Pillar One

  • By Danish Mehboob¬†

The OECD's two-pillar proposal to address the tax challenges of the digitalized economy are technically different, but it is unlikely that one pillarwould be adoptedwithout the other, according to the OECD's Pascal Saint-Amans.

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Doubts Over Arms Length Pricing Rise Amid COVID-19

  • By Josh White & Mattias Cruz Cano

By: Joshwhite & Mattias Cruz Cano

Businesses are finding it difficult to dealwith transfer pricing (TP) data and how to apply an arm's length analysis in a global economy that looked completely different just six months ago.

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EU Moves One Step Closer to DAC7 With Anti-Fraud Tax Package 

  • By Alice Jones

The European Union (EU) has released a three-pillar approach for fair and simple taxation that includes a 25-point action plan, a seventh iteration of the Directive on Administrative Cooperation (DAC7), and a good tax governance initiative.

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News Analysis: Fair Digital Taxation: In the Eye of the Beholder

  • By Mindy Herzfeld

Mindy Herzfeld describes the varying opinions onwhat constitutes fair digital taxation, saying most observers agree that current international tax rules don't properly reflect the realities of today's economy and modes of doing business.

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BEPS Initiatives May Hit Ireland Harder Than Expected

  • By Kiarra M. Strocko

TheOECD's base erosion and profit-shifting initiatives and international tax changes may affect Irish corporate tax revenue over the medium term by more than the ÔøΩ2 billion previously estimated by Ireland'sDepartment of Finance.

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Indonesia Defends Digital Tax Plans Against U.S. Investigation

  • By Stephanie Soong Johnston

TheIndonesian governmentintends to implement an electronic transaction tax thatwould take into account consensus on a global approach to modernize corporate tax rules, and remains "open to dialogue" about its plans.

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OECD Aims to Have Global Tax Deal Blueprints Ready in October

  • By Stephanie Soong Johnston

Work on global tax reform has advanced to the point that blueprints may be ready by October, setting the stage for agreement after the U.S. election, possibly in 2021, theOECD's tax chief said.

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U.S. to Hit Back at French Digital Tax With New Tariffs in 2021

  • By Stephanie Soong Johnston

The U.S.will slap extra 25 percent tariffs on $1.3 billionworth of French goods, including handbags and cosmetics, in retaliation against France's digital services taxÔøΩ but those dutieswill be suspended until January 2021.

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Final FDII Regs Offer Significant Changes to Documentation Rules

  • By Andrew Velarde

Treasuryand theIRShave significantly altered the documentation rules for the foreign-derived intangible income provision in their final regs, relaxing them in some circumstances.

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Pillars 1 and 2: African Perspectives

  • By Victor Adegite and Aimee Dushime

In this article, the authors examine the key elements of theOECD's proposed two-pillar approach to taxing the digital economy from the perspective of African countries.

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EU Renews Support for OECD Digital Taxation Talks

  • By Jean Comte

The EU is committed toworkingwith theOECDto address the issue of digital taxation, according to theEU Council's draft terms of reference for the July 18G-20meeting.

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OECDs CbC Reporting Data Show Ongoing Profit Shifting

  • By Ryan Finley

Aggregated data collected by the OECD that cover almost 4,000 multinationals' country-by-country report filings suggest that the base erosion and profit-shifting project hasn't yet achieved its goal of aligning profitwith value creation.

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New Gig Economy Rules May Contain Unilateral Measures, OECD Says

  • By Stephanie Soong Johnston and Amanda Athanasiou

NewOECDmodel rules for requiring platform operators likeUberandAirbnbto report data on their sellers to tax administrations contemplate automatic information exchange and implications for indirect and other taxes.

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Trade Spokeswoman Warns Multinationals About Expanded DSTs

  • By Annagabriella Colon

Companies that have been exempt under the digital services tax models of theEUand France could find themselves liable under expanded DST regimes being considered by other countries in response to the COVID-19 pandemic.

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U.K. Lower House of Parliament Passes Digital Services Tax

  • By Stephanie Soong Johnston

The House of Commons, the lower house ofthe U.K. Parliament, has passed legislation for a controversial digital services tax, bringing it one step closer to becoming law.

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Problems With GLOBE: Scratching the Surface

  • By Mindy Herzfeld

Mindy Herzfeld looks at potential problemswith OECD pillar 2 arising from differences between financial account and tax system goals in building a global minimum tax base and the separate problem that arises in trying to reconcile these differences.

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Its a matter of fairness: squeezing more tax from multinationals

  • By Yabby Kinder and Emma Agyemang

The cost of the coronavirus crisis means governmentswant to reduce tax avoidance by business.

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Irish finance minister urges EU not to give up on global tax talks

  • By Mehreen Khan and Sam Fleming

Paschal Donohoe, Ireland's finance minister, haswarned the EU against giving up on a global initiative to extract more tax from digital companies as he makes his pitch to lead the group of eurozone finance ministers.

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Report to Show Digital Tax Deal Near, OECD Official Says

  • By Alex M. Parker

The OECD should be able to unveil a solution in October on new digital taxation rules, showing that jurisdictions are close to an agreement despite recent hiccups.

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Tax Authorities More Open to Audit Negotiation 

  • By Mattias Cruz Cano

Some cash-strapped tax administrations are choosing to close audits and settle disputes instead of pursuing court battles, suggesting that collaborationwill trump confrontation post-pandemic.

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Indias Expanded Equalisation Levy Risks Scaring Away MNEs

  • By Mattias Cruz Cano

India's decision to expand the scope of the equalisation levy risks chasing away multinational enterprises (MNEs) at a timewhen the country is trying to revive the crisis-stricken economy.

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4 Ways COVID-19 Could Impact Global Tax in the Long Term

  • By Natalie Olivo¬†

The economic fallout from the novel coronavirus pandemic is likely to reverberate for years, shifting the international tax landscape as U.S. companies grapplewith losses, legislation and other factors that could complicate planning, including intellectual property placement.

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US Tariff Threats May Harm Alliance, EU Finance Ministers Say

  • By Matt Thompson¬†

The finance ministers of four European countries havewritten to the U.S. Treasury secretary, saying that threats by the U.S. to impose tariffs in response to national tax policies of other countries may affect future relationshipwith European countries.

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