Int'l Tax News

By Thomas Horst

In this article, the author estimates the actual revenue effects of four international provisions of the Tax Cuts and Jobs Act and compares his estimates to the projections made by the Joint Committee on Taxation staff in December 2017.

By Barry Larking

Barry Larking compares the different group taxation regimes in the European Union, focusing on the Netherlands' current group taxation regime,which it is considering abolishing.

By Rogerio Abdala Bittencourt Jr. and Antonio José Ferreira Levenhagen

Rogerio Abdala Bittencourt Jr. and Antonio José Ferreira Levenhagen discuss how Brazil can align its tax ruleswith international standards in the areas of fiscal and financial secrecy, tax evasion, avoidance, and aggressive tax planning in preparation for accession to the OECD.

By Annagabriella Colon

Four months after requesting comments about individual and corporate tax morale, the OECD has finalized a report outlining factors that influence tax compliance, stressing the importance of such information for developing countries.

By Ryan Finley

The distinction between residual and routine profit that forms an integral part of some OECD proposals for new profit allocation rules is fundamentally flawed, according to a report by the BEPS Monitoring Group.

By Stephanie Soong Johnston

A conservatively high threshold for excess profits in an OECD approach to tax the digital economy could be an appropriate departure from the arm's-length principle and nexus standards, a top U.S. Treasury official said.

By Reuven S. Avi-Yonah and Kimberly Clausing

Reuven S. Avi-Yonah and Kimberly Clausing make a case for the United States to adopt a sales-based formulary apportionment solution for all large enterprises,whichwould provide a more stable outcome than OECD proposals for taxing the digital economy.

By Stephanie Soong Johnston

Countries are less keen on introducing unilateral measures now that an OECD-led multilateral approach to adapt the international tax rules to the digital age is imminent, according to the OECD's top official.

By Tax Analyst

In a September 9 letter, Sens. Amy Klobuchar, D-Minn., Chris Van Hollen, D-Md., and Tammy Duckworth, D-Ill., alongwith Rep. Peter A. DeFazio, D-Ore., asked Treasury Secretary Steven Mnuchin and IRS Commissioner Charles Rettigwhat steps they are taking to "mitigate the incentives for offshoring created by the 2017 tax law."

The Dutch government said Tuesday it plans to reform a business tax rule that allowswealthy multinationals to reduce the amount of tax they pay on their profits. The government said the plan,which has to be passed by parliament,will generate 265 million euros ($292 million) per year in new income. The announcement follows public outrage at revelations this year that some multinationals paid little or no tax on their profits.​

Tech giant Google said Thursday it has paid over one billion dollars to French authorities to settle a years-long dispute over allegations of tax fraud. A Paris court approved a penalty of 500 million euros ($551 million) from the digital giant over charges of tax evasion, and Google said it paid a further 465 million euros ($513 million) in "additional taxes."

By Victoria Perry, Alexander Klemm, and Shafik Hebous

Efficiency-improving tax reforms in German are possible, ideally to address the domestic tax competition and complexities arising from having both a federal and a municipal corporate income tax, and in any event through technical reforms to address certain inconsistencies that have arisen in the interaction of anti-avoidance provisionswith other tax laws.

By Steven C.wrappe and Marenglen Marku

In this article, the authors detail how tariff costs affect transfer pricing analyses, and they examine the best options available to companies in the absence of meaningful tax guidance.

By H. David Rosenbloom and Fadi Shaheen

In this article, the authors examine how corporate tax changes implemented by the Tax Cuts and Jobs Act interactwith U.S. tax treaties.

By Teri Sprackland

Abandoning permanent establishment as a basis for taxation could reduce France's tax base, a governmentwatchdog haswarned.

By Carrie Brandon Elliot

Carrie Elliot describes how a taxpayer's decision to capitalize property into inventory could increase QBAI and decrease GILTI inclusions.

By Mindy Herzfeld

In the first article in a series reviewing provisions that could be included in future tax legislation, Mindy Herzfeld examines proposals from the Obama administration, the 2014 Camp bill, and the 2016 Betterway Blueprint.

By Martin A. Sullivan

In economic analysis, Martin A. Sullivan offers a few generalizations about the tax treatment of global intangible low-taxed income, providing calculations on the effect of changes in profit movement on taxes.

Bywilliam Hoke

Legislation thatwould require foreign companies that provide digital services to Mexicans to pay VATwas published in the parliamentary gazette September 5.

Bywei Zhuang

Wei Zhuang discusses the major regulations to implement BEPS in China and analyzes the impact on tax administration and tax compliance. She also provides an outlook on China's tax administration in combating BEPS.

By Stephanie Soong Johnston

Although countries have not decreased their corporate income tax rates in 2019 as drastically as they did in 2018, those rates continue to converge as countrieswith the highest rates have introduced the most significant cuts.

By Colinwilhelm

Negotiations between the Trump administration and France are continuing over that country's planned tax on digital services, Treasury Secretary Steven Mnuchin said.

By Hamza Ali

A global minimum tax being considered by the OECD could make rules on tax-avoiding hybrid mismatch structures redundant, an official from the organization said.

By Joe Kirwin

Paolo Gentiloni has hiswork cut out for him as the EU's next tax czar, succeeding France's Pierre Moscovici.

By Hamza Ali and Isabel Gottlieb

A global plan to rewrite how the digital economy is taxed could create new conflicts between countries hoping for a bigger bite of multinationals' profits.

By Joshwingrove and Caitlinwebber

Treasury Secretary Steven Mnuchin told reporters that trade talkswith France are goingwell and that the administration is reaching out to industry groups on digital tax proposals over the comingweeks.

By Jan Stojaspal

Poland has delayed plans to roll out its own digital tax on global tech companies.

By Siraphob Thanthong-Knight

Thailand's new stimulus package aimed at attracting companies and manufacturers to the countrywill be submitted for Cabinet's approval on Sept. 10, Kobsak Pootrakool, a deputy secretary-general in the Thai premier's office, said after an economic ministers' meeting in Bangkok.

The United States is meetingwith technology and other companies as it considers its options following a rowwith Paris over France's tax on big internet firms, the U.S. Treasury secretary said on Monday. Steven Mnuchin told reporters at thewhite House that effortswere ongoing after the two sides agreed at the G7 summit to seek an agreement in the next 90 days,with digital companies meetingwith U.S. Treasury officials thisweek and multinational firms coming nextweek.

Mexico is in talks to extend a sales tax to foreign online businesses so that they pay their fair share to Latin America's second biggest economy, the government said on Monday, in a move that could affect companies like Amazon.com Inc, Uber Technologies Inc and Airbnb Inc.

The move from principle-based approaches to mechanical-based approaches could expose multinationals to permanent instances of over-taxation or double taxation under BEPS Action 4 across jurisdictions.

Ireland has released a responses document on an ongoing consultation on an update to the country's transfer pricing rules. In February 2019, a public consultationwas launched to gather the views of stakeholders regarding a proposed update of Ireland's transfer pricing rules. The update is intended to respond to recommendations from the Coffey review and is also intended to incorporate the 2017 OECD Transfer Pricing Guidelines into Irish legislation.

The pace of tax reform has slowed across most leading economies, a new report from the OECD says, calling for bolder tax reforms to address future challenges. Tax Policy Reforms 2019 describes the latest tax reforms across all OECD countries, aswell as in Argentina, Indonesia, and South Africa. The report identifies major tax policy trends and highlights that fewer countries have introduced comprehensive tax reform packages in 2019 comparedwith previous years.

Businesses areworried that greater transparencywould increase risks and uncertainty if there is a UK general election in the comingweeks and the Labour Party takes power and introduces public country-by-country reporting (CbCR).

EU and US businesses are investing more in Dutch operations owing to slowing business growth conditions from a US-China tradewar, Brexit, and unilateral digital service taxes.

Brookings Papers, ByEmmanuel Saez and Gabriel Zucman

The paper discusses the progressive taxation of householdwealth. The paper discuss: (i)whatwealth is, how it is distributed, and how much revenue a progressivewealth tax could generate in the United States, (ii) the role awealth tax can play to increase the overall progressivity of the US tax system, (iii) the empirical evidence onwealth tax avoidance and evasion aswell as tax enforcement policies, (iv) the real economic effects ofwealth taxation on inequality, the capital stock, and economic activity, and (v) present a simple tractable model of the taxation of billionaires'wealth that can be applied to the Forbes list of the 400 richest Americans since 1982. The model applied to the Forbes data illustrates the long-run effects ofwealth taxation on topfortunes.

By Jan Stojaspal

The Czech Republic refined its draft proposal for a 7% tax on global tech companies to exclude smaller market players.

By Karlis Salna

Indonesia's plan to cut corporate taxes received cautious support from economists and credit rating analysts.

By Hamza Ali

Australia's tax authority has proposed that the country's 10% goods and services tax apply to digital services, such as online advertising.

By Siri Bulusu

The Indian government signed 26 advance pricing agreements (APAs) in the first quarter of the 2019 financial year, according to a government release.

By James Munson

Alberta's drive to become the lowest-taxed region for corporations in Canada may not bring the aimed-for economic revival, skeptical economists say.

By Sony Kassam

Tax authoritieswant their slice of the billions of dollars of untaxed revenue flowing through platforms like Amazon.com Inc. and Netflix Inc. Their plan: To enlist banks, credit card companies and mobile payment providers to help them collect it.

By Sony Kassam

France, India, and China must ensure that multinational companies not headquartered in those countries file global tax reportswith tax administrations there onlywhen OECD guidelines call for it, the organization said.

By James Regan (Bloomberg) and Isabel Gottlieb (Bloomberg Tax)

French Finance Minister Bruno Le Maire had "very constructive discussion"with U.S. counterpart Steven Mnuchin about digital tax, he said on Twitter.

By Emily L. Foster

Proposed regulations clarifying the exceptions from tax on the sales by foreign pension funds that invest in U.S. real estate require several changes, according to the New York State Bar Association Tax Section.

By Ryan Finley

IRS officials are aware of the possibility that antiavoidance provisions of the global intangible low-taxed income and participation exemption regulations could create double gain recognition and are looking for appropriateways to avoid that result.

By Tax Analyst

The number of jurisdictions that have implemented country-by-country reporting has increased, and nearly all large multinational enterprises are now under scrutiny under the standard, the OECD said in its latest round of peer reviews.

Swedish Finance Minister Magdalena Andersson said on Saturday the centre-left coalition governmentwould introduce a bank tax to help fund greater defence spending from 2022. The Social Democrats and Greens said on Friday they had agreedwith the Centre and Liberal Parties,which back them in parliament, to boost defence spending by 5 billion Swedish crowns ($520 million) a year from 2022 to 2025.

On August 29, 2019, German Economy Minister Peter Altmaier announced the outlines of a plan to reduce the tax and regulatory burden on small and medium-sized companies in Germany. In presenting the SME Strategy, Altmaier proposed reducing the tax burden on SMEs through a gradual phasing out of the solidarity tax, and by limiting the level of corporate tax paid by such firms to 25 percent of profits. Altmaier also called for a tax ceiling for private companies,whichwould limit their overall tax burden to 45 percent.