Posted on
U.N. Tax Convention Draft Ignores EU Early Protocol Criticisms
The latest draft setting out terms of reference for a U.N. framework convention on international tax cooperation does not account for EU concerns that early protocols should be negotiated separately from the convention.
Posted on
Will U.K. Taxes Differ Under Labour?
Robert Goulder comments on the Labour Party’s victory and the rise of Chancellor of the Exchequer Rachel Reeves.
Posted on
Inverting to Escape Latin American Instability
In news analysis, Lee A. Sheppard examines inversions from the perspective of closely held business owners attempting to restructure their corporate entities to escape the effects of political instability.
Posted on
OECD Issues Document Package With ICAP Submission Templates
The OECD has released a package of pre-application templates to assist multinational groups with their international compliance assurance program applications, which must contain specific information and overviews of transactions.
Posted on
Amount B at Finish Line Amid OECD’s Busy Agenda
The OECD is already eyeing other pressing profit attribution issues, including those related to global mobility, now that only minor items for a mandatory amount B still need to be negotiated, an OECD official has said.
Posted on
GLOBE Permanent Safe Harbor Idea May Boost EU Competitiveness
A corporate proposal for a permanent country-by-country reporting safe harbor under the pillar 2 global anti-base-erosion rules could help make the EU more business friendly, according to a European Commission official.
Posted on
OECD Aiming to Publish Amount B Country Opt-In List in Autumn
The OECD is working on identifying jurisdictions that are planning on adopting the optional amount B transfer pricing simplification framework and will likely release a list in October, an OECD official said.
Posted on
EU Official Promises a More Business-Friendly Commission
The European Commission’s tax decluttering and pro-competitiveness agenda will probably enhance its business-friendly image and build a bridge between pillar 2 and the anti-tax-avoidance directive, an EU official said.
Posted on
BEPS Activity May Have Declined in Tax Havens, OECD Reports
Multinational enterprises may have reduced their base erosion and profit-shifting activity in the past few years, but the practice is still ongoing, according to the most recent country-by-country reporting data.
Posted on
Digital Music Giants Take Canada's Streaming Tax to Court
Three multinational music streaming companies have mounted a challenge to a Canadian streaming services tax in federal court, according to a digital music advocacy group that claims the levy is bad policy.
Posted on
Left Group to Chair European Parliament’s Tax Committee
The European Parliament’s political groups have decided that a member of the Left Group will succeed Paul Tang as chair of the EP’s subcommittee on tax matters.
Posted on
Hong Kong Implements New Patent Box Regime
Hong Kong’s government has gazetted legislation establishing a patent box granting preferential tax treatment for qualifying income from intellectual property and IT.
Posted on
Taxation of Foreign Branches
In this symposium paper, the UF Tax Incubator working group examines the U.S. approach to taxing income earned through foreign branches, and it explores ongoing issues and potential reforms.
Posted on
Trade Groups Urge U.S. Action as Canadian DST Moves Forward
Business groups are sounding the alarm on potential trade and economic damage from Canada’s digital services tax following the issuance of a coming-into-force order by the Canadian government.
Posted on
EU and U.S. Tariffs on Chinese EVs: Same Approach, Different Result
Robert Goulder comments on the new EU tariffs directed at Chinese EVs.
Posted on
High Taxes Not a Barrier to Competitiveness, EU Commission Says
The view that low taxation increases investment is evolving, according to the European Commission, raising the question whether corporate tax can influence EU countries' competitiveness.
Posted on
Netflix, Disney Ask Canada Appeal Court to Stop Proposed Tax on Streaming Revenue
Netflix, Walt Disney, and other U.S. streaming companies have asked a Canadian court to stop plans by authorities to force them to fork over 5% of their sales in the country to finance local broadcast news and other domestic content.
Posted on
Canada Enacts Digital-Services Tax Amid Risks of U.S. Trade Retaliation
Canada authorized the implementation of a digital-services tax, a move that threatens to trigger trade retaliation from Congress and the Biden administration.
Posted on
Still No Easy Digital Tax Answers for Developing Countries
Nana Ama Sarfo reviews the latest research commissioned by the South Centre, African Union, African Tax Administration Forum, and West African Tax Administration Forum into the amount of revenue developing countries might raise from amount A versus a digital services tax.
Posted on
Hungarian Prime Minister Calls Pillar 2 ‘Catastrophic Failure’
Introducing a global minimum tax rate for the largest multinational enterprises is a “catastrophic failure” because it burdens businesses and dampens EU competitiveness, according to Hungarian Prime Minister Viktor Orbán.
Posted on
OECD Tax Chief Still Optimistic After Missed Pillar 1 Deadline
The end-of-June deadline for countries to conclude pillar 1 tax reform negotiations has come and gone, but delegates are still making good headway toward a final agreement, the OECD’s tax director said.
Posted on
India, United States Confirm Digital Tax Compromise Extension
India has joined the group of countries that have extended the “unilateral measures compromise” with the United States that outlines a transitional approach to their digital services taxes before pillar 1 rules are implemented.
Posted on
Canada’s Enactment of Pillar 2 — Part I
Nathan Boidman, Michael N. Kandev, and Marc André Gaudreau Duval, in the first installment of a two-part analysis, provide an overview of, and context for, the Global Minimum Tax Act — legislation now moving through Canada’s Parliament to implement pillar 2. Part two will more closely examine certain aspects of the legislation with a focus on provisions that yield interpretational issues or deal with antiavoidance.
Posted on
U.N. Makes Progress Toward a Framework Convention on International Tax Cooperation
Hafiz Choudhury explains efforts at the U.N. to foster an international taxation cooperation process more inclusive of developing countries. The opinions expressed in this article are solely those of the author and do not reflect the views of any other person or organization, in particular the U.N.
Posted on
Virtual Permanent Establishment — A New Nexus to Tax?
Aditi Goyal and Kanupriya Sharma explore the concept of “virtual permanent establishment” as a framework for taxation in an increasingly digital world, using the Clifford Chance case in India as a primary example.
Posted on
OECD Secretariat Looks to Permanent Safe Harbors
More OECD focus on developing permanent safe harbors for pillar 2 minimum tax rules could decrease the need and volume of administrative guidance going forward, according to an OECD tax official.
Posted on
EU Tax Chief Urges Rich Countries to Participate in U.N. Process
High-income countries should engage constructively in U.N. discussions to develop a framework convention on international tax cooperation or risk a global spread of tension in tax policymaking, a top EU tax official said.
Posted on
US Unwilling to Compromise on Key Provision of Global Tax Deal, Treasury Official Says
The U.S. is set on making Amount B, which deals with companies’ marketing and distribution activities, mandatory even as several other countries are pushing to make it optional.
Posted on
Canadian Parliament Approves Controversial Digital Services Tax
The Canadian Parliament has passed a highly controversial 3 percent digital services tax on large businesses, sparking calls from U.S. trade groups for Canada to reconsider.
Posted on
Countries’ Differing Court Remedies Present Harmonization Challenges
Policymakers have spent more than a decade crafting an international consensus on the allocation of corporate tax revenue, but the scattered landscape for settling tax cases could undermine the goal of a smoothly operating system.
Posted on
Supreme Court Upholds Trump-Era Tax Provision
The dispute, which was closely watched by experts, involved a one-time foreign income tax, but many saw it as a broader challenge to pre-emptively block Congress from passing a wealth tax.
Posted on
Supreme Court Upholds 2017 Tax on Foreign Investments
The court rejected a challenge from conservative activists to a one-time tax on certain foreign investments but left unresolved questions about whether some leading Democratic revenue-raising ideas are constitutional.
Posted on
The Next Phase of Pillar 2 Implementation: Creative Competition
Mindy Herzfeld examines what countries are doing to maintain competitiveness as pillar 2 makes offering fiscal incentives a fraught undertaking.
Posted on
G7 Confirms Target for Opening Pillar 1 Convention for Signature
The leaders of the G7 countries are aiming to open the pillar 1 multilateral convention for signature by the end of June.
Posted on
Digital Barter Taxes: A Legal Defense
Young Ran (Christine) Kim with Cardozo School of Law and Darien Shanske with the University of California, Davis, continue their argument that a digital barter tax is a good idea and examine possible legal arguments and challenges.
Posted on
Turkey Studies New Taxes Worth $7 Billion That Target Corporates
Turkish lawmakers have drafted new tax proposals aimed mostly at companies, seeking to repair a budget buffeted by last year’s earthquakes, in what would be the biggest overhaul in a generation.
Posted on
Norway’s Tax-the-Rich Drive Provokes Widening Business Backlash
Norway’s planned clampdown on the nation’s wealthiest citizens is provoking a backlash from entrepreneurs who warn the measure will just worsen the economy’s heavy dependence on oil and gas.
Posted on
G-7 Leaders Reaffirm Support for Finalizing Global Tax Agreement
In a communique at their summit in Italy, the G-7 leaders said they hope the treaty will be open for signature by the end of June, as OECD officials have said. The G-7 leaders also called for further progress on the implementation of the OECD’s global minimum tax.
Posted on
Turkey Postpones Tax Related to Stocks Trading After Criticism
Turkish Finance Minister Mehmet Simsek said the government has postponed plans to introduce a “very limited” transaction tax on stock trading, after push back from traders.
Posted on
Keir Starmer sets out plans to raise £8.6bn in tax at Labour manifesto launch
Sir Keir Starmer, UK opposition party leader, set out plans to raise £8.6bn in tax in the Labour manifesto on Thursday as he promised to “relight the fires” of economic growth and bring “Conservative chaos” to an end.
Posted on
Denmark Plans Tax Cuts for Entrepreneurs, Drops ‘Phantom’ Tax
The Danish government presents a plan to significantly lower taxes for entrepreneurs, in a move to bolster the startup scene in the Nordic country, particularly in the biotech industry.
Posted on
Saudis May Ease Tax Rules to Boost Appeal of Bonds to Foreigners
Saudi Arabia laid out a series of steps it plans to take to boost its debt capital market, including a possible easing in taxes it hopes will make local corporate bonds more appealing to foreign investors.
Posted on
Private equity firms have amassed $1tn in ‘carry’ fees as taxation debate mounts
According to new research from Oxford university, the world’s largest private capital firms have avoided income taxes on more than $1tn in incentive fees since 2000 by structuring the payments in a way that subjected them to a much lower levy.
Posted on
European Commission Expands Tasks of Good Tax Governance Platform
The European Commission has added fair and efficient taxation, cross-border taxation, and double nontaxation to its renewed Platform for Good Tax Governance and is accepting applications for membership to its new expert group.
Posted on
Trudeau’s Rival Opposes Capital Gains Hike, Promises Tax Cut
Canadian Conservative Leader Pierre Poilievre said he would vote against the government’s proposal to raise the capital gains tax inclusion rate, ending weeks of speculation about where he would land on the issue.
Posted on
Report Expects Global, Digital Taxes to Collect Similar Revenue
Posted on
Tech Industry Groups Push for Trade Dispute Over Canada’s Digital Services Tax
A coalition of technology and industry associations with business ties to Canada asked the Office of the U.S. Trade Representative to initiate a formal trade dispute in an effort to block Ottawa’s digital services tax.
Posted on
U.N. Tax Convention Could Focus on Taxation of Multinationals
A new U.N. framework convention could include high-level commitments on the fair allocation of taxing rights among countries, including the taxation of multinational enterprises and high-net-worth individuals.
Posted on
UN Draft Tax Treaty Urges Fairer Taxing Rights, Wealth Taxes
A UN committee has provided countries with a preliminary document for negotiating a global tax treaty, naming fair taxation of corporations and wealth taxes as areas of focus.
Posted on
Brazil’s Tax Change to Shift Soybean Demand to US, Amius Says
A surprising tax change in agriculture powerhouse Brazil has the potential to make soy grown in the world’s largest bean exporter less competitive with supplies from the US, according to a report from risk management firm Amius Ltd.