Int'l Tax News

Lucas de Lima Carvalho considers that maybe the income inclusion rule isn’t so bad when it’s compared with the undertaxed payments rule.

Leopoldo Parada examines the Court of Justice of the European Union’s rejection of the European Commission’s use of an autonomous EU arm’s-length standard and the Court’s move to set limits on the use of the OECD transfer pricing guidelines to identify a selective advantage under EU state aid law in the Court’s recent Amazon decision.

After raising tax on stock options, India projects to collect 12.5% more in security transaction tax in 2025.

Ryan Finley explains why the cost-sharing regulations’ definition of “platform contribution” shouldn't be interpreted as a restriction on specified methods other than the income method.

The country expects to generate A$160 million in fiscal year 2025-26 and A$210 million in fiscal year 2026-27 from the 15% tax on Australian multinational parent and subsidiary companies with at least 750 million euros in annual global revenue.

Some members of the European Parliament want the Business in Europe: Framework for Income Taxation proposal to include a formula for dividing the tax pie among EU member states.

Reuven S. Avi-Yonah examines what’s next for the United States and U.S. multinationals as pillar 2 becomes a reality.

As a country with only a handful of ultimate parent entities of groups that qualify for minimum taxation, Latvia is allowed a deferral of full European Union rules ensuring a global minimum level of taxation for multinational groups and large national groups.

Mindy Herzfeld examines whether Treasury’s recent efforts to clarify when U.S. taxpayers may claim a foreign tax credit contradicts U.S. law and congressional mandates.

While transfer pricing revenues reverted to pre-pandemic figures at £1.6 billion, results from the diverted profits tax appear to be highly cyclical, yielding only £40 million in tax year 2022–2023, HM Revenue & Customs said.

An Australian mining advocacy group has urged the commonwealth to adopt tax credits to contend with the movement of critical minerals investments to the United States as a result of the Inflation Reduction Act.

Michelle Markham examines the methods different countries are using to enhance tax certainty by exploring recent developments in multilateral avenues for improving international tax dispute resolution.

Companies using the International Compliance Assurance Program assessed risks faster than with other legal tools and were able to obtain more certainty about their tax bills.

Nine EU member states face infringement proceedings after missing a key deadline to communicate to the European Commission about measures transposing the pillar 2 global minimum tax directive into their national laws.

The adoption of a proposed common EU corporate tax system should be delayed until pillar 2 rules are comprehensively implemented and pillar 1 talks are finalized, business groups told the European Commission.

Reuven S. Avi-Yonah explores the history of the corporate tax as an excise versus income tax and explains potential effects from the Moore and Altria cases.

Allison Christians examines a recent Tax Court of Canada decision that took an unusual approach to treaty shopping.

Carrie Brandon Elliot reviews prop. reg. section 1.987-1(b), which addresses foreign currency gains and losses of foreign branches using functional currencies that differ from that of their owners.

An OECD official told the European Parliament’s subcommittee on tax matters that the way capital gains are taxed in OECD countries could lead to tax minimization strategies, inequities, and the loss of revenues.

Sweden’s interest limitation rule that denies an interest deduction for a cross-border intercompany loan to finance an intragroup reorganization violates the freedom of establishment guaranteed by the EU treaty, a Swedish court has held.

Paul W. Oosterhuis offers proposals for determining which taxes the multinational tax community can agree are properly imposed as income taxes and proposals for determining what taxes other countries should defer to, either through foreign tax credits or income exemptions.

Belgian Finance Minister Vincent Van Peteghem told members of the European Parliament that the EU needs to take the lead in the discussion regarding pillar 1 of the OECD’s global corporate tax plan.

Extractives industry groups and other stakeholders have voiced concerns over a recent OECD proposal to amend the model tax convention commentary by including a 30-day permanent establishment threshold for natural resource extraction.

More than 100 tax academics from 17 EU member states are calling for the creation of an EU agency for tax cooperation to facilitate the exchange of information, particularly regarding VAT and excise taxes.

Lee A. Sheppard examines the foreign tax credit recapture and Schedule UTP aspects of Liberty Global and details why the Tax Court rejected Liberty Global’s argument that its capital gain in excess of its overall foreign loss should be exempt from U.S. tax.

Treasury is considering issuing proposed regs on sourcing rules for cloud transactions as companion regulations to finalized rules regarding characterization.

The 2021 global tax agreement could have “a discriminatory impact” by hurting predominantly non-white nations’ ability to collect taxes and pay for vital services for their people, according to nine experts who have been appointed by the UN Human Rights Council to report and advise on human rights issues. 

Philippine Finance Secretary, Ralph Recto, pledged to focus on boosting tax collection and sustaining current spending as he took over the job on Friday in the first revamp of President Ferdinand Marcos Jr.’s economic team since he assumed power in 2022. 

New international tax rules will force multinational companies to pay an extra 6.5% to 8.1% in tax, according to the OECD. The impact will be felt most acutely by companies that use tax havens, euphemistically known as investment hubs. 

The OECD will soon begin working on broader guidance tackling hybrid arbitrage arrangements involving the pillar 2 global anti-base-erosion rules, and it could release that guidance this year, an OECD adviser said.

After soliciting public feedback on the OECD’s multilateral tax treaty in case any important issues were missed, the US does not plan to reopen negotiations of the document, according to a Treasury Department official. However, some consideration as to the definition of terms in the treaty may be made.

The Treasury Department is focused on finding a “principled” way to deal with novel extraterritorial taxes like digital services taxes as it considers changes to its foreign tax credit rules.