Int'l Tax News

By Thomas Horst

Thomas Horst examines the actual revenue effects of four international provisions two years after the enactment of the Tax Cuts and Jobs Act.

By Ryan Finley

Although the European Commission had mixed success defending its Starbucks and Fiat state aid decisions in court, both decisions' broad endorsement of the commission's legal theories may significantly hinder the ongoing appeal of the Apple decision.

Foreign companies targeted by Mexico's VAT reforms are evaluating the potential losses they face from the burdensome and costly measures. Companies may exit the Mexican market if talkswith the government fail.

Mark Martin and Thomas Bettge of KPMG in the US examine recent OECD statistics on mutual agreement procedure cases, showing that such cases continue to be resolved effectively both in the US and around theworld.

By Ara Stepanyan and Steven D. Felgran

Ara Stepanyan and Steven D. Felgran propose an approach to profit allocation or formulary apportionment that builds on the concept of people functions, using employees' measurable contributions on the supply side and consumers' measurable contributions on the demand side.

By Lee A. Sheppard

In news analysis, Lee A. Sheppard describes how Luxembourg and Irelandwill implement the hybrid mismatch rules required by the EU's second anti-tax-avoidance directive.

By Mindy Herzfeld

Mindy Herzfeld examines the French digital services tax that's expected to primarily affect large U.S. tech companies and the various options the United States has to combat it.

By Rick Minor

In this article, the author considers incoming European Commission President Ursula von der Leyen's College of Commissioners and the formal tax priorities of her commission.

By H. David Rosenbloom and Fadi Shaneen

H. David Rosenbloom and Fadi Shaheen examine how changes implemented by the Tax Cuts and Jobs Act interactwith U.S. tax treaties.

By Ryan Finley

An EU court has annulled the European Commission's ÔøΩ26 million recovery order for aid allegedly granted by the Netherlands to Starbucks through an advance pricing agreementwhile dismissing Luxembourg's appeal of the commission's Fiat decision.

By Annagabriella Colon

Final passage of the long-pending Chile-U.S. tax treaty may hinge on its amendment via a protocol to account for the base erosion and profit-shifting provisions of the U.S. Tax Cuts and Jobs Act.

By Jad Chamseddine

The Senate Foreign Relations Committee chair hopes the Senatewill approve more tax treaties this year, but he expects delays.

By Elodie Lamer

The incoming EU tax commissioner has promised to use the controversial article 116 of the Treaty on the Functioning of the European Union to circumvent the EU Council's unanimity rule in taxation.

By Stephanie Soong Johnston

France's draft 2020 budget proposed billions in tax cuts, including a ÔøΩ1 billion decrease for companies, but it did not impress some business groups,which said itwas unlikely to boost competitiveness and investment.

By Lee A. Sheppard

Lee A. Sheppard previews the upcoming final BEAT regulations and predicts some of the changes that might be made to the proposed guidance.

By Chetan Vagholkar and Eric Horvitz

In this article, the authors summarize some good, bad, and ugly results of making the global intangible low-taxed income high-tax exception election under the proposed regulations.

ByJoe Kirwin

European Union member countries are divided overwhether the bloc's proposals for a common corporate tax base and new anti-tax abuse provisionswould apply to all companies or only to large multinationals.

By Helene Fouquet

France's former digital affairs ministerwants to force internet giants like Amazon, Alphabet, Microsoft, Facebook and Apple to reveal how much profit they make in France, saying the companies are understating their French activities to a vast extent.

Proposals from the OECD, a forum for research and debate among mostly rich countries, provide a promising basis for a new model. Theywould give governments a "tax right" over the profits of consumer-facing businesses depending on the share of saleswithin their territory.

An under-the-radar proposal from the Organization for Economic Cooperation and Development to stem income shifting could require a new degree of information sharing, something experts saywould be either a difficult obstacle or a new chapter in theworld's shift toward tax transparency. The OECD's proposal, part of its sweeping digital tax project, is similar to the 2017 U.S. base erosion and anti-abuse tax andwould aim to reduce deductions on payments meant to shift income out of a jurisdiction. But, unlike the BEAT, itwould hinge on a calculation of how much the payment is taxed in the receiving jurisdiction.

On September 17, 2019, Dutch State Secretary for Finance Menno Snel presented the Government's 2020 Tax Plan to the House of Representatives. It includes revised plans for corporate tax cuts. Under legislation approved in December 2018, the rate of corporate tax on income exceeding EUR200,000 (USD221,000)was due to fall from 25 percent to 22.55 percent in 2020 and to 20.5 percent in 2021. However, under the new proposals, corporate tax above this thresholdwill remain at 25 percent next year, before falling to 21.7 percent in 2021.

Sandra Benedetto and Fernando Binder analyse several amendments made by the Chilean government to the Tax Bill submitted to Congress in August last year, one ofwhich seeks to tax digital serviceswith value added tax (VAT).

The technology, media and telecommunications (TMT) sector may be directly affected by the G20/OECD digital economy tax proposals. Sajeev Sidher and Kaidi Liu of Deloitte Tax LLP look at the uncertainties ahead.

Starbucks haswon its case against the European Commission's 2015 state aid decision today, but the EC clawed back awin against Fiat Chrysler in two conflicting cases over the use of the transactional net margin method.

Taxpayers and advisors say Brazil's proposal to overhaul the multiple indirect tax regimes and rates into a single system have a good chance of succeeding because of the need for simpler tax rules. But progresswill be slow.

By Stephanie Soong Johnsto

The Tax Cuts and Jobs Act's global intangible low-taxed income provision must be treated as a compliant minimum tax in any OECD proposal to adapt international tax rules to the digital age, CEOs said.

By Tax Analyst

The Business Roundtable, a nonprofit U.S. organization, urged the Organization for Economic Cooperation and Development to continue to oppose double taxation, promote effective dispute resolution, and minimize changes to profit allocation and rules on the right to tax,while they are considered as international tax rule changes.

By Ryan Finley

Although Ireland does not oppose the OECD's efforts to modernize the international tax system, the government believes that the existing transfer pricing framework must be preserved, according to Irish Minister for Finance Paschal Donohoe.

By Tax Analyst

In a September 17 overview of a General Court of the European Union hearing of a case regarding the European Commission's 2016 decision finding Ireland granted illegal state aid to Apple Sales International and Apple Operations Europe, Ireland's Department of Finance noted that they are contesting the decision on the basis that they have not given favorable tax treatment or granted state aid to Apple or its subsidiaries.

By Tax Analyst

The Dutch government introduced its 2020 tax plan on September 17, outlining implementation of a national climate agreement, income tax and VAT cuts, and a corporation tax rate increase.

By Teri Sprackland

If an international agreement on digital taxation is not reached next year, the next European Commissionwill propose a Europeanweb tax, the incoming EU tax commissioner said.

By Andrew Goodall

Reducing U.K. corporation tax to 17 percent in 2020 is a stupid policy that has had no impact on investment decisions, according to Susan Kramer, Liberal Democrat Treasury spokeswoman in the House of Lords.

By Isabel Gottlieb

Theworld's biggest polluting countries aren't doing enough to tax carbon consumption and encourage cleaner energy, an OECD report found.

By Linda Thompson

Dutch opposition lawmakers are pressing the government to abandon plans to cut the headline corporate tax rate by almost four percentage points in 2021.

By Aoifewhite and Stephanie Bodoni

Apple Inc. and Ireland's court room clashwith the European Commission finally lived up to its billing as theworld's biggest tax case.

By Siri Bulusu

Sen. Amy Klobuchar has asked Treasury if it is taking steps to block companies from offshoring jobs because of tax incentives.

Taxing capital holdings boosts rewards for investingwell.

Apple 's ÔøΩ13 billion ($14.4 billion) tax fightwith Europe is grinding through the courts. It could end up generating unwelcome headlinesÔøΩfor Apple and Brussels alike.whatwas a story about the European Union hittingwhat it sees as an undertaxed technology giant has turned into a tussle for billions in tax revenue between Brussels andwashington. The shift is awkward for European officials,who are seeking to avoid a tradewarwith President Trump.

Italian taxpayers evaluate the benefits of a new option in the patent box regime allowing companies to make autonomous calculations of tax benefits.

The Indian government on Friday announced a slew of concessions aimed at boosting the economy thatwill reduce most corporate taxes for local companies to about 25% from 30%. Finance Minister Nirmala Sitharaman said the lower tax rateswill retroactively apply from April 1, the beginning of India's fiscal year.

By Joe Kirwin

European Union finance ministers meeting in Helskini agreed to consider adopting a carbon border tax on imports coming from countries that didn't commit to the Paris Agreement.

By Hamza Ali

A global minimum tax thatwill ensure tech giants "pay their fair share" is on the horizon, Germany's finance minister Olaf Scholz said in at meeting in Finland.

By Jessica Shankleman

The opposition Labour Partywould seek to expand a tax on financial transactions if it is elected to government, according to the party's Treasury spokesman John McDonnell.

By Stephanie Bodoni

Google got a boost in a tax case at the European Union's top court that's made the search-engine giant an unlikely ally of EU antitrust chief Margrethe Vestager in a clashwith Hungary.

By Andrea Navarro

Mexico's tax collectors are taking a big step in their bid to get a piece of the booming digital economy pie.

By Joe Stanley-Smith

The OECDwill for the first time rank countries on how effectively they negotiate to resolve tax disputes, a top tax official from the organization said.

By Siri Bulusu and Hamza Ali

Up to 24 governments could be in the firing line of punishing U.S. trade policies if they go aheadwith their individual digital tax plans, a senior U.S. Treasury officialwarned.

By Isabel Gottlieb

Fresh details on the OECD's digital tax projectwill be out early October, but a full analysis of its impact on countries' revenueswon't be ready this year, the group's tax chief said.

By Hamza Ali

The U.S. Treasury has urged the OECD not to narrowly focus on industries like social media in its recommendations to reform theway countries tax the digital economy.

By Patrick McGee and Javier Espinoza

The iPhone's appeal to its ÔøΩ13bn fine is heard sameweek as its latest product launch.