Int'l Tax News

A European Union-wide tax on theworld's top digital companies could be reached by the end of March, French Finance Minister Bruno Le Maire said in an interview published on Sunday.

The advisory board taskedwith reporting on the state of Switzerland's financial center has recommended changes to the country'swithholding tax and property tax regimes.

The common consolidated corporate tax base (CCCTB) and digital services tax (DST) could be introduced if the EU Commission's proposal for qualified majority voting (QMV) succeeds.

Gibraltar recently enacted the Income Tax Act 2010 (Amendment No. 3) Regulations 2018,which introduced a new limitation on the deductibility of interest on debt.

New York corporate taxpayers now have some guidance on global intangible low-taxed income after the state's tax department quietly updated its filing instructions for business corporate franchise tax returns.

Austria has announced plans to impose a 3 percent tax on online advertising. It also plans to levy VAT on all goods sold online by third-country retailers and to strengthen reporting obligations for online platforms.

The Netherlands' top finance official is touting his newwithholding tax on interest and royalties as a key anti-tax-avoidance measure, but he is also eyeing France and Germany's minimum tax proposal to possibly complement it.

Tax reform in the European Union needs to move faster than the unanimity requirement permits, according to a think tank that has endorsed a controversial remedy requiring unanimous approval.

The European Commission's plan to eliminate the veto that EU governments hold over any of its tax initiatives faces a major obstacle: the veto.

UK authorities are mounting a new crackdown on tax avoidance by multinational companies, inviting businesses they suspect of flouting the rules to come forward and settle their affairs.

Monaco joined 17 other jurisdictions that have ratified the Organization for Economic Cooperation and Development's ambitious super-tax treaty to crack down on corporate base erosion and profit-shifting.

Stock buyers in Europewould pay a transaction tax of at least 0.2 percent of the purchase price under a plan set out by Germany and France.

Austria's proposed 3 percent tax on online advertising revenue could net more companies than Google Inc. and Facebook Inc., tax practitionerswarn. Any company that operates in Austria, sells online advertisingwithin the countryÔøΩand has a global revenue of at least 750 million euros ($834 million) and domestic revenue of 10 million eurosÔøΩwill be subject to the tax, the government announced Jan. 10.

Austria plans to cut 4.5 billion euros ($5.2 billion) in taxes -- about 1.5 percent of economic output -- in the next three years as it tries to deliver on Chancellor Sebastian Kurz's campaign promiseswhile keeping the budget on track for a surplus. To balance against the cuts, Austriawill introduce a new 3 percent tax on Internet advertising revenuewith additional measures targeting global online giants like Alphabet Inc., Facebook Inc. and Amazon.com Inc.

Perrigo Co Plc. is considering shelving expansion plans in Ireland after tax authorities slapped the drugmakerwith a 1.6 billion euro ($1.8 billion) demand, a person familiarwith the matter said.

The European Commission estimates that the requirement for all member countries to vote for new tax laws has cost the single market 242 billion euros ($277.5 billion) in lost tax revenue, in a Jan. 14 proposal calling for the abolition of national veto powers in favor of a qualified majority.

The European Commissionwill invite EU governments to gradually relinquish their national vetoes on tax policy matters, according to draft of "communication" set to be unveiled on Tuesday and obtained by Bloomberg.

Germany should try to head off an economic slowdown by easing the tax burden on companies, according to the new chairwoman of Chancellor Angela Merkel's Christian Democrats. Germany's federal budget surpluswidened to more than 11 billion euros ($12.6 billion) last year, fueling debate about tax cutswithin the ruling coalition of Merkel's conservatives and the Social Democrats.

Indonesia's plan to tax e-commerce transactions is drawing resistance from the country's largest online retailers,which argue the levywill throttle the growth of a nascent industry that's drawn billions of dollars in foreign investment.

Steven Garden, Garywilcox, and Jeffrey Bruns of Mayer Brown discuss the proposed regulations intended to flesh out the interest deduction limitations under new tax code Section 163(j). The authors say the proposed regulations are thoughtful but long and complicated and include a very broad definition of interest.

One of the principal U.S. tax policy issues leading up to the Tax Cuts and Jobs Actwas how foreign-source active business income of U.S. multinational enterprises should be taxed by the U.S. if the system of deferring U.S. tax on active foreign income of a foreign subsidiarywas ended. Much of the U.S. multinational business community urged adoption of a territorial or exemption system,while others, including many labor-backed groups, favored adopting an expandedworldwide tax regime. Congress chose both. This report takes a preliminary look at the extent towhich the TCJA's purely outbound international provisions caused a degree of movement in either direction. The authors have concluded that expandedworldwide taxation is the normatively preferred position. The report explains how the new global intangible low-taxed income regime may serve as a platform to shift the U.S. international tax regime to expandedworldwide taxation and identifies steps thatwould accomplish that objective.

More than a year after passage of the 2017 tax overhaul, multinational companies like Nike Inc. andwalgreens Boots Alliance, Inc. still aren't surewhat the new rules mean for their bottom linesÔøΩsetting up a bumpy ride through the upcoming earnings season. Companies are stillwaiting for the government to answer questions about the law's international provisions so they can calculate their tax bills properly.

The European Commissionwill launch the findings of a consultation into replacing veto powers on tax policywith a qualified majority voting system Jan. 15. The move could pave theway for the European Union to pass key tax laws such as the digital services tax and the financial transaction tax,which up to now have been stalled since the policy for tax measures requires unanimity from all member countries, and means some countries could block significant laws through exercising their right to veto.

Bermudian Finance Minister Curtis Dickinson issued the Economic Substance Regulations 2018 on December 28, aweek after the passage of the Economic Substance Act. The regulations took effect December 31.

Special counsel Robert Mueller is looking intowhether any foreign money illegally flowed to President Trump's inaugural committee. In August 2018 the U.S. District Court for the Southern District of New York obtained a guilty plea from awashington consultantwho used a U.S. citizen to purchase inauguration tickets so that a foreign person could attend the inauguration. Donations to an inaugural committee, including ticket purchases, can't come from foreign persons (see Rebecca Davis O'Brien, Rebecca Ballhaus, and Aruna Viswanatha, "Trump Inauguration Spending Under Criminal Investigation by Federal Prosecutors," Thewall Street Journal, Dec. 13, 2018).

The OECD is committed to finding reasonable solutions for addressing digital taxation this year. As previously reported, the organization has been considering a three-pronged approach involving a proposal for a minimum tax, favored by the Germans and the French; a proposal for a shift to destination-based source rules, favored by the United States; and a proposal for allocating taxing rights based on user location, favored by the United Kingdom.

In the realms of the beaten, there's the Red Devils, and there's service providers,which are looking at being beaten down by . . . BEAT. That'd be the new Tax Cuts and Jobs Act base erosion and antiabuse tax (section 59A). Proposed regulations interpreting this new lawwere issued on December 13 (REG-104259-18).

Chile isweighing proposals for a new tax of up to 19 percent on multinational digital commerce companieswith local operations Finance Minister Felipe Larrain said on Thursday, a rate nearly double that originally proposed.

This article discusseswhat the Sustainable Development Goals ("SDGs") are,what the role of (corporate) taxation is in reaching these goals andwhy both in-house tax practitioners and thoseworking in a law firm or advisory firm should pay close attention to the SDGs.

Alibaba has blocked 200,000 vendors globally since September in response to governmental pressure for the Chinese e-commerce giant to crack down on tax avoiders using its platform.

Mexicowill cut the tax rate paid by companies on the proceeds of initial public offerings to 10 percent as part of a broad-ranging plan to boost public offerings and spur growth in the financial system.

Amazon, Facebook, and other American technology giants could owe Italy hundreds of thousands of dollars under a new digital-revenue tax lawmakers approved as part of the country's 2019 budget.

The U.K. tax office is giving companies a chance to avoid a 30 percent penalty if they disclose their exposure to the "Google" tax through a new notification program.

Brussels has launched a probe intowhether Nike benefited from sweetheart tax arrangements in the Netherlands that breached EU curbs on state support.

Nike Inc. is the latest U.S. giant to become embroiled in the European Union's crackdown on tax deals regulators say give a select group of big firms an unfair edge over their rivals.

Money collected from the U.S. government's new import tariffs helped offset the loss of revenue it suffered from corporate tax reductions, according to estimates published Jan. 8 by the Congressional Budget Office.

The American Institute of CPAs has addressed issues in proposed regulations (REG-104390-18) on global intangible low-taxed income that include the carryforward of net tested losses by U.S. shareholders, anti-abuse rules, and the availability of the section 245A dividends received deduction to controlled foreign corporations.

The Organization for Economic Cooperation and Development held a meetingwith the Netherlands that focused on international cooperationwithin the tax field and the adoption of measures by the Dutch government to update the international tax system and address tax evasion.

In this article, the author examines the relationship between Greece's general antiavoidance rule and the GAAR included in the EU's anti-tax-avoidance directive.

Thailand has implemented a new international business center (IBC) tax regime in linewith action 5 (harmful tax practices) of the OECD's base erosion and profit-shifting project.

Recently released guidance on the base erosion and antiabuse tax may have provided taxpayerswith much-needed detail, but practitioners are not fully satisfiedwith answers provided on base erosion payment operating rules.

On January 15 the European Commissionwill present a communication setting out options to move from unanimity to qualified majority voting in tax matters.