Posted on
EU Won't Introduce Pillar 1 Directive, Commission Official Says
The European Commission has decided against proposing a directive to implement pillar 1 of the OECD’s two-pillar global tax reform plan because the pillar 1 multilateral convention would be enough, an EU official said.
Posted on
Barbados Minister Criticizes Use Of Tax Transparency Blacklists
A minister from Barbados discouraged countries from blacklisting others based on how far they’ve developed their tax transparency frameworks.
Posted on
EU Nearing Full Pillar Two Implementation, But Not Pillar One
European Union countries are largely on track to start applying Pillar Two of the global tax deal next year, but the finalization of Pillar One remains uncertain, an EU official said at a European Tax Adviser Federation seminar.
Posted on
Promising Tax Talks Face Hurdles as Taiwan Bills Go Their Own Way
Tax talks that would combine a beefed-up child tax credit and reinstate full research and development expensing aren’t exactly sizzling, but they are picking up speed after a year in the doldrums.
Posted on
UK Minimum Tax Estimates Are Highly Uncertain, Economist Says
The UK’s projection of £12.7 billion ($15.9 billion) in revenue within the next six years from the global minimum tax is highly uncertain, a top budget economist told lawmakers in a government budget hearing Tuesday.
Posted on
More European Governments Propose Global Minimum Tax Bills
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.
Posted on
IP Transfers and Profit Shifting
Martin A. Sullivan explores financial data for more than 300 multinational companies to uncover trends in intellectual property transfers.
Posted on
U.K. Makes Full Expensing Business 'Tax Cut' Permanent
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.
Posted on
U.N. Tax Cooperation Resolution Passes in Committee Vote
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.
Posted on
EU to Assess Support for Withholding Tax Relief Framework Deal
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.
Posted on
Colombia’s Introduction of Tax Arbitration a ‘Big Advance’
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.
Posted on
UK Sees About $16 Billion From Global Minimum Tax Over Six Years
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.
Posted on
As Its Economy Sputters, Britain Cuts Taxes Ahead of Election
The U.K.’s top financial official, Jeremy Hunt, outlined measures to spur business investment and push more people into jobs.
Posted on
Barbados's Evolving Approach to Pillar 2
Nana Ama Sarfo discusses Barbados's changing approach to pillar 2.
Posted on
Canada Reaffirms Its Plans for Unilateral DST
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.
Posted on
UN Releases Draft Tax Resolution Calling for Framework Treaty
A draft resolution released by the UN calls for the development of a framework convention to make international tax cooperation more inclusive.
Posted on
Corporate Income Tax Rates Decreased Globally Over Last 20 Years
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.
Posted on
EU to Consider Making Unshell Substance Test a Minimum Standard
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.
Posted on
Report Reveals Hidden Costs of Canada's Battery Plant Subsidies
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.
Posted on
Switzerland Mulls Later Start Date for Global Minimum Tax
Switzerland may postpone raising the minimum tax rate on multinationals to 15%, amid widespread delays in implementing a global deal on the issue.
Posted on
U.S. Signs Indo-Pacific Tax Transparency Pact
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.
Posted on
Bermuda Seeks Input on Draft Corporate Tax Legislation
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.
Posted on
Vote on U.N. Tax Cooperation Resolution Expected Soon
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.
Posted on
African Nations Call on Rich Countries to Back UN Tax Reform
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.
Posted on
Much Ado: Why the United States Should Calm Down About DSTs
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.
Posted on
Chile Senate Votes to Ratify Tax Treaty with US, Advancing Pact
Chile’s Senate unanimously approved a tax treaty with the US, bringing the agreement one step closer to taking effect.
Posted on
US Corporate AMT: Inbound Investors Beware of Aggregation Rules
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.
Posted on
EU Mulls Expansion of Sectors Targeted by Carbon Border Tax
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.
Posted on
House Lawmakers Call for Extension of Foreign Tax Credit Relief
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.
Posted on
Pillar 2 and Foreign Tax Credits
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.
Posted on
OECD Status Check
Mindy Herzfeld examines the latest developments in the OECD’s international tax work, including the two-pillar project.
Posted on
OECD Cryptoasset Framework to Come Into Force in 2027
In order to address potential gaps in existing information exchange, 48 countries have formally signed on to the OECD’s cryptoasset reporting framework.
Posted on
German Parliament Passes Global Minimum Tax Legislation
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.
Posted on
Finland Consults on Signing Pillar 1 Multilateral Convention
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.
Posted on
Nigeria Seeks to Lure Foreign Investment With Tax Incentives
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.
Posted on
48 Countries Commit To Global Crypto Tax Reporting In 2027
Forty-eight countries said Friday they are moving ahead with implementing a global crypto-asset reporting framework by 2027.
Posted on
IRS Issues New Foreign Currency Regs
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.
Posted on
Chile’s Lower House Approves US Tax Treaty, Sending It to Senate
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.
Posted on
Finland Government Seeks Public’s Opinion on Global Tax Treaty
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.
Posted on
Recent OECD Guidance on Minimum Tax Aligns With EU Tax Rule
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.
Posted on
Barbados to Adopt Pillar 2 Domestic Minimum Tax in 2024
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.
Posted on
The End of the Brazilian Interest on Equity Benefit?
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.
Posted on
Brazil Tackles One of World’s Most Complicated Tax Codes
Brazil’s senate approved a reform to simplify one of the world’s most byzantine tax codes.
Posted on
Countries’ Tax Info Needs To Be Made More Available, Forum Says
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.
Posted on
FTC Pillar 2 Guidance and Relief Extension to Be Issued Together
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.
Posted on
Lavish Tax Credits and Trade Protections Lure Solar Firms to U.S.
A combination of government policies is finally succeeding in reversing a long decline in solar manufacturing in the United States.
Posted on
Possible Foreign Tax Credit Fix to Come After Minimum Tax Guidance
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.
Posted on
Ship Has Sailed on Pillar 2, EU Committee Warns U.S. Congress
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.
Posted on
Italy Adopts Novel Pillar 2 Dispute Resolution Measure
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.
Posted on
U.S. Economist Defends IRA Against Calls for Carbon Tax
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.