Skip to main content

Int'l Tax News

Posted on

G-24 Looks Beyond OECD Tax Reforms and Toward the U.N.

  • By Stephanie Soong

The two-pillar OECD tax reform plan doesn’t go far enough to help developing countries, so the G-24 is hopeful for more progress under a U.N. framework convention for international tax cooperation, the group’s director said.

To read more go here Subscription Required

Posted on

Stakeholders Say Australian Public CbC Reporting Requires Conformity

  • By Nana Ama Sarfo

Nana Ama Sarfo reviews some responses to Australia's most recent public country-by-country reporting consultation and notes how the measure raises larger questions about international standardization.

To read more go here Subscription Required

Posted on

European Commission Gets Mixed Messages Regarding Tax Wish List

  • By Elodie Lamer

EU leaders plan to adopt a draft statement calling for the harmonization of corporate tax law to advance the Capital Markets Union, but the European Commission’s meetings with tax officials tell a different story.

To read more go here Subscription Required

Posted on

Try Again: The Problems of BEFIT

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah suggests that the EU adopt the pillar 1 three-factor formula for BEFIT and apply it to large multinationals operating in the EU.

To read more go here Subscription Required

Posted on

Over 100 Large Companies Report Possible Adverse Pillar 2 Effects

  • By Martin A. Sullivan

Martin A. Sullivan examines how companies are addressing the effects of pillar 2 in their financial reports, using the “Magnificent 7” to show various approaches.

To read more go here Subscription Required

Posted on

Can the United States Protect Its Tax Base From Withholding Taxes?

  • By Mindy Herzfeld

Mindy Herzfeld cautions that the United States’ tax base could erode in the wake of a global push for broad-based withholding taxes on services.

To read more go here Subscription Required

Posted on

Moves to Adopt Pillar 2 Will Help U.S. in OECD Guidance Talks

  • By Stephanie Soong

U.S. progress on implementing OECD global minimum tax rules would put American negotiators in a better position to ask for U.S.-friendly pillar 2 administrative guidance, according to a top Treasury official.

To read more go here Subscription Required

Posted on

EU Talks on Remote Workers Show Progress Is Possible on PEs

  • By Elodie Lamer

An EU task force looking at taxing rights over remote teleworkers appears to be leaning toward bilateral arrangements, and the possibility of triggering permanent establishments is a recurring theme in the talks.

To read more go here Subscription Required

Posted on

JCT Mulling Ways to Refine U.S. Pillar 2 Revenue Estimates

  • By Stephanie Soong

The Joint Committee on Taxation is monitoring the implementation of global minimum tax rules around the world as it considers how to update its analysis of pillar 2’s potential U.S. revenue effects.

To read more go here Subscription Required

Posted on

Proposed Irish Foreign Dividend Exemption Is Work in Progress

  • By Sarah Paez

The Irish Finance Department has published a draft proposal for a participation exemption for foreign dividends that draws on feedback from a government consultation.

To read more go here Subscription Required

Posted on

Taiwan-U.S. Double Tax Matters — Finding a Solution

  • By Arlene S. Fitzpatrick

Arlene S. Fitzpatrick provides context for various proposals to address the Taiwan-U.S. tax relationship and explains the merits of the options available to navigate this landscape.

To read more go here Subscription Required

Posted on

Ireland Suggests Limits to New Dividend Tax Exemption

  • By Danish Mehboob

Ireland wants to circumscribe its incoming corporate tax break for dividend income to tax treaty countries in the latest “strawman” version of the proposal with scope and administration details.

To read more go here Subscription Required

Posted on

Canada Studies IP Box Initiative


Nathan Boidman, Marc André Gaudreau Duval, and Michael N. Kandev give an overview of IP box regimes, discuss whether it would be advantageous for Canada to adopt one, and examine the Canadian government’s perspective on the issue.

To read more go here Subscription Required

Posted on

Netherlands Seeks Alternatives for Raising Bank, Dividend Taxes

  • By Danish Mehboob

A top Dutch tax official suggested tweaks to the country’s corporation tax to replace the higher bank tax and upcoming dividend tax on stock buybacks.

To read more go here Subscription Required

Posted on

Top Treasury Official Argues for US to Adopt Global Minimum Tax

  • By Lauren Vella

Acting Deputy Assistant Secretary for International Affairs at the Treasury, Scott Levine, said the US should adopt an income inclusion rule or reform its current global intangible low-taxed income rule, known as GILTI, so that it is compliant with the global minimum tax rules and provides more tax certainty to corporations.

To read more go here Subscription Required

Posted on

Is Treasury Bound by the Arm’s-Length Standard?

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah examines the history of the arm’s-length standard and considers whether Treasury can deviate from it if it is necessary to clearly reflect related taxpayers’ income.

To read more go here Subscription Required

Posted on

AI Tools Are Changing Tax Enforcement Policy in Latin America

  • By Ignacio Gepp

Ignacio Gepp, lawyer at Puente Sur, assess Latin America’s use of AI in tax administration and potential consequences to taxpayer rights.

To read more go here Subscription Required

Posted on

Senate Wins Fight With House Over OECD Budget

  • By Doug Sword

House appropriators tried to punish the OECD for its tax policies by eliminating its federal funding for fiscal 2024, but the organization instead got a 4 percent budget boost, according to a State Department document.

To read more go here Subscription Required

Posted on

Liechtenstein Approves Ordinance Clarifying Pillar 2 Legislation

  • By Sarah Paez

The Liechtenstein government has approved an ordinance that clarifies the interpretation and implementation of the country’s new law implementing a global minimum tax on large corporate groups.

To read more go here Subscription Required

Posted on

The Implementation of Global Minimum Tax in ASEAN Countries

  • By Melani Dewi Astuti

Melani Dewi Astuti provides a status check on Southeast Asian countries’ adoption of the global anti-base-erosion rules and examines the challenges these countries face in the wake of pillar 2, including limitations on offering tax incentives.

To read more go here Subscription Required

Posted on

Swiss Tax Authorities Turn Focus to Transfer Pricing Issues

  • By Thomas Hug

Pressure from EU and recent international tax developments have led Switzerland to align its national tax system with new international standards by focusing on transfer pricing provisions.

To read more go here Subscription Required

Posted on

Norway’s Carbon Tax Exemptions May Be State Aid, Watchdog Warns

  • By Stephen Gardner

Norway may have breached state aid rules by granting carbon tax exemptions for some waste incineration and some industrial uses of natural gas and liquefied petroleum gas, the authority that oversees Norway’s compliance with European Union single market rules said.

To read more go here Subscription Required

Posted on

OECD Misses Deadline for Deal on Final Global Tax Treaty

  • By Lauren Vella

The OECD continues negotiations over the global tax treaty, after missing a March 31 deadline to agree on the convention’s final text. Issues that remain unresolved include withholding taxes and the definition of digital service taxes.

To read more go here Subscription Required

Posted on

HMRC undermining innovation by failing to award R&D tax credits, say start-ups

  • By Yasemin Craggs Mersinoglu

UK start-ups and small businesses have accused HM Revenue & Customs of putting economic growth and innovation at risk by rejecting legitimate claims for research and development tax relief, delaying payments and clawing back credits. The result has left companies exploring options to move overseas or scrapping plans to create jobs or invest.

To read more go here Subscription Required

Posted on

New Zealand Adopts Global Minimum Tax as Part of Omnibus Law

  • By Stephen Gardner

New Zealand finalized a law that will introduce the global minimum corporate income tax of 15%, via an income inclusion rule and an undertaxed profits rule. The income inclusion rule will apply to New Zealand-headquartered multinationals, and the undertaxed profits rule will apply a top-up tax on foreign companies that operate in New Zealand but are taxed below 15% in their home jurisdictions.

To read more go here Subscription Required

Posted on

OECD Mulls Using Risk Assessment Tool for Global Tax Deal

  • By Lauren Vella

The OECD is considering using one of its existing tools to provide taxpayers the ability to gain more certainty about their positions if they are subject to the global minimum tax and other provisions under the global tax deal.

To read more go here Subscription Required

Posted on

Ecommerce tariffs will kick in from 2026, says WTO chief

  • By Andy Bounds

The first customs duties on digital products such as online films and software downloads will hit consumers and businesses in 2026, increasing prices in some countries, the head of the World Trade Organization has predicted. 

To read more go here Subscription Required

Posted on

China Files WTO Complaint Over US Electric-Vehicle Subsidies

  • By James Mayger

China filed a complaint to the World Trade Organization alleging the US’ Inflation Reduction Act and associated rules are “discriminatory” and have “seriously distorted” the global EV supply chain by blocking electric-vehicle manufacturers from sourcing materials from China and other foreign adversaries.

To read more go here Subscription Required

Posted on

OECD to Soon Release Updated Pillar 2 Commentary, Official Says

  • By Stephanie Soong

The OECD expects to publish in the coming weeks updated commentary for the pillar 2 global anti-base-erosion rules that will incorporate previous rounds of administrative guidance, an OECD official said.

To read more go here Subscription Required

Posted on

EU Council Presidency Closing In on FASTER Directive

  • By Elodie Lamer

The list of outstanding issues in the European Commission's Faster and Safer Relief of Excess Withholding Taxes proposal is narrowing, but EU member states are still divided over which transactions to exclude from the text.

To read more go here Subscription Required

Posted on

Holdout Jurisdictions Opposing U.S. Pillar 1 Goals, Levine Says

  • By Stephanie Soong

The United States is trying to secure key conditions for Congress to support a pillar 1 tax agreement, but it is at odds with a few major jurisdictions, according to a Treasury official.

To read more go here Subscription Required

Posted on

EU Likely Won’t Ratify U.N. Tax Convention if It Undoes OECD Work

  • By Kiarra M. Strocko and Sarah Paez

The EU will engage with the U.N. tax cooperation process to reach a broad consensus, an EU tax official said, stressing that the process should not undo important work on the OECD two-pillar plan.

To read more go here Subscription Required

Posted on

Germany Passes €3.2 Billion Bill to Ease Burden on Business

  • By Kamil Kowalcze

The law aims to ease the burden of taxation and bureaucracy to strengthen the country’s competitiveness as a business location, with Europe’s biggest economy struggling to generate growth.

To read more go here Subscription Required

Posted on

Netherlands Suggests Topics UN Should Tackle in Tax Convention

  • By Danish Mehboob

The Netherlands is recommending that work on the United Nations tax treaty meet sustainable development goals and be consistent with the Organization for Economic Cooperation and Development’s tax work without duplicating it.

To read more go here Subscription Required

Posted on

European Commission Proposes Path to End Unanimity in Tax Votes

  • By Sarah Paez

The European Commission has raised the possibility of moving the EU Council from unanimity to qualified majority voting on tax and other matters as part of a strategy for integrating new member states.

To read more go here Subscription Required

Posted on

Italy Might Retain and Modify DST if Pillar 1 Isn’t Implemented

  • By William Hoke

Italy’s economy minister said his country might retain and modify its digital services tax if efforts to implement pillar 1 of the OECD’s two-pillar global tax reform plans come to naught.

To read more go here Subscription Required

Posted on

Saint-Amans Suggests External Tax Borders to Fund EU Budget

  • By Elodie Lamer

Pillar 2 of the OECD’s global tax reform plan could have presented an opportunity to merge resources for the EU budget — for example, through the undertaxed profits rule — according to an international tax expert.

To read more go here Subscription Required

Posted on

Italy Suggests Revamping Digital Tax If OECD Treaty Not Agreed

  • By Danish Mehboob

Italian Finance Minister Giancarlo Giorgetti told the country’s Chamber of Deputies on Wednesday that signing the Organization for Economic Cooperation and Development’s treaty looks problematic because of the political dynamics in some large countries, including the US, that are crucial to finalizing the deal.

To read more go here Subscription Required

Posted on

UK Eyes Carbon Tax Rollout in 2027, Seeks Comments on Process

  • By Danish Mehboob

The UK government aims to introduce its carbon border tax on Jan. 1, 2027, and is seeking feedback on its design, implementation, and administration—including the scope of products and ways to calculate emissions.

To read more go here Subscription Required

Posted on

Treasury Aiming for Research Credit Fix in Pillar 2 Guidance

  • By Stephanie Soong

The United States is working to protect the benefits of the research credit under pillar 2 global minimum tax, possibly through OECD administrative guidance, a top Treasury official said.

To read more go here Subscription Required

Posted on

Offering Refundable Tax Credits Is Not ‘Gaming’ the GLOBE Rules

  • By Jefferson Vanderwolk

Jefferson VanderWolk takes exception to criticism of the use of refundable tax credits, explaining that in fact refundable tax credits are a legitimate policy response to the current GLOBE rules.

To read more go here Subscription Required

Posted on

EU Could Axe Unanimity Rule For Tax Files, Commission Suggests

  • By Stephen Gardner

The EU commission says rules on voting procedures do not need to be changed, but EU countries could agree to activate a procedure allowed by the rules under which a unanimous decision could be taken to permit qualified majority decisions in some areas currently subject to unanimity, including tax.

To read more go here Subscription Required

Posted on

EU Prepares for Future Talks With U.K. on Harmful Tax Practices

  • By Elodie Lamer

The EU will soon put in motion a 2020 commitment to hold annual talks with the United Kingdom regarding measures to counter harmful tax practices, according to a draft European Commission/EU Council statement.

To read more go here Subscription Required

Posted on

Biden’s Climate Law Has Created a Growing Market for Green Tax Credits

  • By Jim Tankersley

New Treasury Department data shows companies have registered 45,500 projects for possible sale on a new tax-credit marketplace.

To read more go here Subscription Required

Posted on

Funding Needed to Make U.N. Tax Talks Inclusive, Colombia Says

  • By Elodie Lamer

The terms of reference for a proposed U.N. convention on international tax cooperation should provide for funding to ensure that the least developed countries can attend upcoming negotiations in New York, a Colombian official said.

To read more go here Subscription Required

Posted on

The BEPS Project: Superhero or Supervillain?

  • By Peter Mason

Peter Mason reviews the latest report by the OECD on corporate tax statistics to assess the impact of the base erosion and profit-shifting project.

To read more go here Subscription Required

Posted on

UAE Wants Corporate Feedback On Global Minimum Tax Policy

  • By Danish Mehboob

The United Arab Emirates is consulting on the global minimum tax framework, including policy options for the extraterritorial rules. The UAE wants feedback on how the framework interacts with the country’s new corporate tax system and implementation of rules which ensure the top-up tax is collected on foreign in-scope entities too.

To read more go here Subscription Required

Posted on

Australia Tax Info Reporting Plan Gets Pushback From Tax Groups

  • By Deborah Nesbitt

Australia should exempt multinational companies from reporting tax information from each country where they have operations if they’re not required to report it at home, tax and accounting firms told the Treasury department.

To read more go here Subscription Required

Posted on

Transfer Pricing Under Global Minimum Tax Poses Double Tax Risk

  • By Danish Mehboob

If companies make transfer pricing adjustments after the end of the year, as many do, they could be disqualified from using a safe harbor that simplifies the global minimum tax’s calculations and reduces their tax liabilities.

To read more go here Subscription Required

Posted on

France Starts Offering Big Tax Credit To Aid Green Investments

  • By Danish Mehboob

France started offering its green industry tax credit to companies to offset costs up to €350 million ($381 million) per qualified investment in energy. The tax credit is expected to generate €23 billion in investments, create 40,000 jobs, and cut 35 million tons of CO2 emissions by 2030.

To read more go here Subscription Required
Back to top