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Int'l Tax News

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More European Governments Propose Global Minimum Tax Bills

  • By Stephanie Soong

The Austrian, Norwegian, and Slovenian governments have proposed legislation implementing an EU directive for adopting global minimum tax rules under pillar 2 of the OECD’s two-pillar global tax reform plan.

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IP Transfers and Profit Shifting

  • By Martin A. Sullivan

Martin A. Sullivan explores financial data for more than 300 multinational companies to uncover trends in intellectual property transfers.

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U.K. Makes Full Expensing Business 'Tax Cut' Permanent

  • By Sarah Paez

The United Kingdom will make full expensing for business capital investments permanent as part of a plan to invest £20 billion annually in businesses over the next decade, said Chancellor of the Exchequer Jeremy Hunt.

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U.N. Tax Cooperation Resolution Passes in Committee Vote

  • By Sarah Paez

U.N. countries passed a resolution in committee to establish a framework convention for international tax cooperation, which would shift negotiations from the OECD to the U.N.

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EU to Assess Support for Withholding Tax Relief Framework Deal

  • By Elodie Lamer

While EU countries generally reacted positively to the Spanish EU Council presidency’s proposal exempting comprehensive withholding tax relief systems from some Faster and Safer Relief of Excess Withholding Taxes provisions, several requested time to study the impact.

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Colombia’s Introduction of Tax Arbitration a ‘Big Advance’

  • By Sam Edwards

Colombia will seek to allow arbitration in tax disputes for the first time in a major step forward, although questions remain about the proposal’s efficacy, tax professionals say.

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UK Sees About $16 Billion From Global Minimum Tax Over Six Years

  • By Danish Mehboob

The UK government estimates it will net about £12.7 billion ($15.9 billion) from the global minimum tax over the next six years, according to figures published in its Autumn budget statement.

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As Its Economy Sputters, Britain Cuts Taxes Ahead of Election

  • By Eshe Nelson

The U.K.’s top financial official, Jeremy Hunt, outlined measures to spur business investment and push more people into jobs.

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Barbados's Evolving Approach to Pillar 2

  • By Nana Ama Sarfo

Nana Ama Sarfo discusses Barbados's changing approach to pillar 2.

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Canada Reaffirms Its Plans for Unilateral DST

  • By Amanda Athanasiou

Despite opposition from business groups and the Biden administration, Canada has confirmed its intent to move ahead with its digital services tax just weeks before its planned effective date.

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UN Releases Draft Tax Resolution Calling for Framework Treaty

  • By Lauren Vella

A draft resolution released by the UN calls for the development of a framework convention to make international tax cooperation more inclusive.

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Corporate Income Tax Rates Decreased Globally Over Last 20 Years

  • By Lauren Vella

Income tax rates for companies have decreased on average over the past 23 years, according to a report on corporate tax statistics released by the OECD on Tuesday.

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EU to Consider Making Unshell Substance Test a Minimum Standard

  • By Elodie Lamer

A note prepared by the EU Council's Spanish presidency suggests pursuing the European Commission's idea to maintain the tax consequences of its proposal to tackle the misuse of shell entities.

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Report Reveals Hidden Costs of Canada's Battery Plant Subsidies

  • By Amanda Athanasiou

The cost of government support for electric vehicle battery manufacturing projects in Canada that includes U.S.-credit-matching subsidies to major automakers could exceed estimates by almost C $6 billion, a budget watchdog said.

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Switzerland Mulls Later Start Date for Global Minimum Tax

  • By Bastian Benrath

Switzerland may postpone raising the minimum tax rate on multinationals to 15%, amid widespread delays in implementing a global deal on the issue.

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U.S. Signs Indo-Pacific Tax Transparency Pact

  • By Alexander Rifaat

The United States has joined 13 other countries from the Indo-Pacific region in agreeing to, among other measures, strengthen cooperation to combat cross-border tax evasion.

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Bermuda Seeks Input on Draft Corporate Tax Legislation

  • By Stephanie Soong

The Bermudian government is holding a third consultation on its proposed corporate tax regime — this time on draft legislation intended to align with the global anti-base-erosion rules under pillar 2.

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Vote on U.N. Tax Cooperation Resolution Expected Soon

  • By Sarah Paez

U.N. members are expected to vote soon on a draft resolution that would lay the groundwork for a legally binding framework convention on international tax cooperation.

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African Nations Call on Rich Countries to Back UN Tax Reform

  • By James Munson

African countries at the United Nations called on richer nations to back their push to have the global body undertake negotiations toward reforming the world’s tax rules.

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Much Ado: Why the United States Should Calm Down About DSTs

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah examines why countries have embraced unilateral digital services taxes and, in light of pillar 1’s grim outlook, how the United States can learn to live with them.

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Chile Senate Votes to Ratify Tax Treaty with US, Advancing Pact

  • By Michael Rapoport

Chile’s Senate unanimously approved a tax treaty with the US, bringing the agreement one step closer to taking effect.

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US Corporate AMT: Inbound Investors Beware of Aggregation Rules

  • By Jennifer Lee, Zachary Kling, Jonathan Rhein, Zaira Cortes Rivero, and Peter A. Glicklich

Enacted as part of the Inflation Reduction Act of 2022, the US Corporate Alternative Minimum Tax is in effect for all tax years beginning after December 31, 2022, but the IRS and taxpayers alike continue to learn more about the contours and pitfalls of the CAMT.

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EU Mulls Expansion of Sectors Targeted by Carbon Border Tax

  • By Lauren Vella

The European Union is considering extending the purview of its carbon border tax to a limited number of other sectors, according to a European Commission official.

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House Lawmakers Call for Extension of Foreign Tax Credit Relief

  • By Chris Cioffi

Democrat and Republican House lawmakers are asking for an additional pause on newer, more stringent foreign tax credit rules, a move the IRS already hinted may be coming.

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Pillar 2 and Foreign Tax Credits

  • By Lee A. Sheppard

Lee A. Sheppard examines the impact of the pillar 2 income inclusion rule, qualified domestic minimum top-up tax, and undertaxed profits rule on the foreign tax credit for U.S. multinationals.

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OECD Status Check

  • By Mindy Herzfeld

Mindy Herzfeld examines the latest developments in the OECD’s international tax work, including the two-pillar project.

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OECD Cryptoasset Framework to Come Into Force in 2027

  • By Michael Smith

In order to address potential gaps in existing information exchange, 48 countries have formally signed on to the OECD’s cryptoasset reporting framework.

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German Parliament Passes Global Minimum Tax Legislation

  • By Stephanie Soong

Germany’s Parliament has approved a law transposing the EU’s global minimum tax directive into national law, in line with pillar 2 of the OECD’s two-pillar plan to modernize the international corporate tax system.

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Finland Consults on Signing Pillar 1 Multilateral Convention

  • By Stephanie Soong

The Finnish government is asking for input on whether it should sign a multilateral convention implementing a reallocation of taxing rights as part of pillar 1 of an OECD-brokered, two-pillar global tax overhaul.

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Nigeria Seeks to Lure Foreign Investment With Tax Incentives

  • By Ruth Olurounbi

Nigeria will boost incentives for foreign investors in an attempt to address a decline in capital coming into the country as part of the government’s plans to revive the economy.

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48 Countries Commit To Global Crypto Tax Reporting In 2027

  • By Danish Mehboob

Forty-eight countries said Friday they are moving ahead with implementing a global crypto-asset reporting framework by 2027.

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IRS Issues New Foreign Currency Regs

  • By Andrew Velarde

After years of delaying the applicability date of earlier regulations, the IRS has released long-awaited proposed regs on income and foreign currency gain or loss for qualified business units.

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Chile’s Lower House Approves US Tax Treaty, Sending It to Senate

  • By Sam Edwards

Chile’s lower house unanimously approved a tax treaty with the US on Wednesday, sending the bill to the Senate, where it could become law in the coming weeks, the Finance Ministry said.

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Finland Government Seeks Public’s Opinion on Global Tax Treaty

  • By Lauren Vella

Finland is requesting opinions from stakeholders on whether the country should sign onto a multilateral tax treaty that’s part of the OECD-led international tax pact.

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Recent OECD Guidance on Minimum Tax Aligns With EU Tax Rule

  • By Stephen Gardner

The European Union reaffirmed its support for the international two-pillar tax deal and confirmed recent guidance on the global minimum tax aligns with the EU’s implementation of the rule, according to a statement issued by finance ministers.

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Barbados to Adopt Pillar 2 Domestic Minimum Tax in 2024

  • By Stephanie Soong

The Barbados government will implement a domestic minimum top-up tax aligned with pillar 2 global minimum tax rules as part of a plan to overhaul its corporate tax system, according to Prime Minister Mia Mottley.

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The End of the Brazilian Interest on Equity Benefit?

  • By Maria Bel, Luis Vargas, and Paulo Vellano

Multinational groups with presence in Brazil should analyze the tax profile of their Brazilian entities in view of the potential elimination of the long-standing interest on equity tax deduction.

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Brazil Tackles One of World’s Most Complicated Tax Codes

  • By Martha Beck and Daniel Carvalho

Brazil’s senate approved a reform to simplify one of the world’s most byzantine tax codes.

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Countries’ Tax Info Needs To Be Made More Available, Forum Says

  • By Danish Mehboob

An international agency monitoring tax transparency reported most of its member countries are complying with tax information exchange standards, but the availability of certain information can be improved.

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FTC Pillar 2 Guidance and Relief Extension to Be Issued Together

  • By Amanda Athanasiou

An IRS official has confirmed that the agency still plans to release foreign tax credit guidance on pillar 2 by year-end and expects to extend temporary relief from final FTC rules at the same time.

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Lavish Tax Credits and Trade Protections Lure Solar Firms to U.S.

  • By Ana Swanson
  • By Jim Tankersley

A combination of government policies is finally succeeding in reversing a long decline in solar manufacturing in the United States.

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Possible Foreign Tax Credit Fix to Come After Minimum Tax Guidance

  • By Michael Rapoport

The IRS plans to go ahead with guidance on how foreign tax credit regulations interact with the new global minimum tax even though it’s still considering whether and how those regulations might be modified, an IRS official said Monday.

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Ship Has Sailed on Pillar 2, EU Committee Warns U.S. Congress

  • By Stephanie Soong

Implementation of global minimum tax rules is happening, and there’s nothing the United States can do to stop it, members of the European Parliament subcommittee on tax matters told U.S. lawmakers.

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Italy Adopts Novel Pillar 2 Dispute Resolution Measure

  • By Stephanie Soong

Italy has introduced an innovative dispute prevention and resolution provision based on the principle of reciprocity as part of its pillar 2 implementation strategy, according to a finance ministry official.

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U.S. Economist Defends IRA Against Calls for Carbon Tax

  • By Amanda Athanasiou

A White House economist has responded to ExxonMobil’s support for a carbon tax by casting serious doubt on the possibility of achieving a global harmonized carbon market without any climate policy deviations.

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Jamaica Plans Domestic Top-Up Tax in Minimum Tax Implementation

  • By Michael Rapoport

Jamaica plans on establishing a qualified domestic minimum top-up tax as part of its implementation of the pending global minimum tax, a Jamaican official said Tuesday.

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US Envoy Warns of Big Fight If Canada Digital Tax Takes Effect

  • By James Munson

The US and Canada are headed toward a “big fight” over Canada’s plans to enact a digital services tax unless a solution is found, US Ambassador David Cohen said Tuesday.

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U.S. Looks to Allay European Fears of a Subsidy War

  • By Alan Rappeport

Wally Adeyemo, the deputy Treasury secretary, said the United States was continuing to look for ways to improve coordination with Europe on climate and energy security initiatives.

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Treasury Wants Different Pillar 2 Treatment for Research Credit

  • By Sarah Paez

The United States considers the treatment of the nonrefundable research credit by the pillar 2 global minimum tax regime an important priority as countries begin to implement the legislation, a Treasury official said.

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Argentina to Push Withholding Tax Absent Pillar 1 Progress

  • By Stephanie Soong

Argentina will be ready to present a proposal for a withholding tax mechanism on digital service providers if progress isn’t made soon on the signing of a multilateral convention implementing pillar 1, an Argentine official said.

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