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German MOF at Odds With OECD Over Intangibles Pricing

  • By Alexander F. Peter

The pricing of intangibles in related-party transactions will cause unsolvable disputes unless the OECD provides revised guidance, according to panelists at the annual Congress of the International Fiscal Association in Cancun, Mexico.

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Bulgaria's Minimum Tax Must Have Substance Carveout, NFTC Says

  • By Stephanie Soong

If Bulgaria doesn’t join other EU member states in including a substance-based carveout in its proposed domestic minimum top-up tax, it will damage its ability to attract foreign investment, a trade group warned.

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Plowgian Asks Taxpayers to Tell Treasury What MLC Draft Got Wrong

  • By Andrew Velarde

A senior Treasury official is offering greater detail on what public input the department is seeking in response to the amount A multilateral convention under pillar 1, including comments on what the draft document got wrong.

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Puerto Rico Explores Global Minimum Tax, Talks With Industry

  • By Angélica Serrano-Román

Puerto Rico is taking steps to be part of the global corporate tax deal’s minimum tax plan, island Treasury Secretary Francisco Parés Alicea said as he moved between meetings in Washington and New York this week to discuss the prospects with companies with a large presence in the local economy.

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Reform US International Taxation Laws to Set a Global Example

  • By Philip G. Cohen

Some recent developments should spur action by Congress to reform US tax laws that address international taxation. Congress did this in 2017 but in an ill-conceived way, and it should be revamped.

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Developing Countries Helped to Build Two-Pillar Plan, OECD Says

  • By Elodie Lamer

During a debate at the EU’s annual tax symposium about the advantages of the OECD's global tax reform plan versus a U.N. tax convention, the OECD said developing countries helped to shape its tax pillars.

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Firms Will Struggle With Pillar 2 and BEFIT, Business Rep Says

  • By Stephanie Soong

Global minimum tax rules and a common EU corporate tax system will likely overload companies’ capacity for compliance because the interplay between the regimes could be overly complex, a business representative warned.

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Netherlands Urged to Seek Alternatives if Pillar 1 Tax Deal Fails

  • By Stephanie Soong

The Netherlands should consider other options in case countries can’t reach agreement soon on the amount A multilateral treaty under pillar 1 of the two-pillar global tax reform plan, a Dutch tax official told parliament.

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U.S. Claims Court Allows Foreign Tax Credit for NII Tax Liability

  • By Michael Smith

The Court of Federal Claims has allowed a U.S. couple residing in France to use the France-U.S. tax treaty to claim a foreign tax credit against their net investment income tax liability.

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A Tax Rule Change Is Threatening the Survival of Some Businesses

  • By Jennifer Williams-Alvarez

Businesses large and small are being hit by a change in tax rules on R&D expenses. Some are struggling to stay afloat.

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OECD Weighing Pillar 2 Deferred Tax Asset Guidance

  • By Sarah Paez
  • By Stephanie Soong

The inclusive framework on base erosion and profit shifting is considering issuing pillar 2 guidance on the treatment of deferred tax assets in jurisdictions with federal and subnational taxes, an OECD official said.

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Tax Concessions Undermine Pillar 2 Tax Rules, EU Study Says

  • By Stephanie Soong

An initial projected revenue increase under pillar 2 global minimum tax rules has diminished because of negotiated concessions like a substance-based carveout and generous treatment of tax credits, according to a sweeping EU study.

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NGOs Criticize EU's Reluctance to Join a U.N. Tax Convention

  • By Elodie Lamer

Nongovernmental organizations have expressed disappointment regarding the EU’s hesitancy about joining a legally binding U.N. tax convention, but EU officials said they believe it would duplicate and could undermine the OECD’s work.

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Multilateralism Crisis Mustn't Spread to Tax, Colombian Adviser Says

  • By Stephanie Soong

Disagreements between the global north and south and debates over whether the U.N. or OECD should lead on tax matters could cause a breakdown in multilateral tax cooperation, a Colombian government adviser warned.

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An Amount B for Developing Countries

  • By Suranjali Tandon
  • By Chetan Rao

Suranjali Tandon and Chetan Rao explain the potential importance of amount B for developing countries and suggest ways that amount B can be improved to address specific developing country needs.

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IRS Heightens Scrutiny of Foreign, Large Corporations


Amplifying its efforts to go after tax dodgers, the IRS Friday announced new efforts to target foreign corporations and the largest corporate taxpayers.

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European Parliament Report Addresses Excess Profits, Inflation

  • By Elodie Lamer

In their compromise report on the role of tax policy in times of crisis, members of the European Parliament have called for a broader excess profits tax net and inflation-adjusted personal income tax brackets.

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Five EU Member States Pursuing Delayed Pillar 2 Implementation

  • By Cady Stanton

Five EU member states have told the European Commission that they plan to avail of the possibility to delay implementation of the pillar 2 directive, a top EU tax official said.

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Bipartisan Taiwan Tax Bill Text Issued by Congress’s Tax Writers

  • By Chris Cioffi

Senate and House tax-writers seeking to encourage cross-border business collaboration between Taiwan and the US released bipartisan bill text Thursday outlining their plan to provide treaty-like benefits through the tax code.

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Ireland Proposes Draft Minimum Tax Rule with Safe Harbor

  • By Stephen Gardner

Ireland released a Treasury bill Thursday with details of its plans to roll out the global minimum tax, a part of the OECD-led global tax deal.

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U.N. Negotiating Draft Resolution on International Tax Convention

  • By Sarah Paez

The United Nations is negotiating a draft resolution to establish a legally binding convention to promote inclusivity for developing countries in international tax cooperation.

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Delegates Push Back on U.N. Work on Pillar 2 and Tax Incentives

  • By Stephanie Soong

The U.N. shouldn’t pursue further work on the potential effects of global minimum tax rules on tax incentives in the extractives industry because it would be inappropriate, several tax committee delegates said.

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Canada’s Digital Services Tax Projected to Raise C$7.2B by 2028

  • By Brian Platt

Canada’s proposed tax on big technology firms could raise as much as C$7.2 billion ($5.3 billion) over five fiscal years, according to a new projection from a parliamentary spending watchdog.

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Treasury Mulls More US Guidance on Global Minimum Tax Issues

  • By Michael Rapoport

The Treasury Department is working on a potential “next push of guidance” on how the US will reconcile some issues relating to the new global minimum tax, a department official said Tuesday.

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Nigeria Files Resolution to Work Toward UN Global Tax Convention

  • By Michael Rapoport

Nigeria filed a draft resolution calling for the United Nations to create an international tax convention, the next step toward the organization potentially assuming a greater role in global tax cooperation.

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EU Adds Three Tax Haven Countries, Cuts Three From Watchlist

  • By Stephen Gardner

European Union finance ministers Tuesday approved an update to the bloc’s list of jurisdictions considered uncooperative on tax, adding three and removing three, leaving the list with 16 entries.

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Works on Pillar 1 Convention Issues to Run Into 2024, Yellen Says

  • By Stephanie Soong
  • By Alexander Rifaat

U.S. Treasury Secretary Janet Yellen indicated countries will work into 2024 to settle issues preventing the signing of the pillar 1 multilateral convention, which would mean a related digital tax freeze will soon expire.

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Global Reallocation Tax Rules Can Be Simplified Later, OECD Says

  • By Danish Mehboob

Computations to reallocate taxing rights to markets under a global treaty might be simplified over time, according to one senior official from the OECD.

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US to Miss Deadline to Avoid Fresh Digital Taxes, Yellen Says

  • By William Horobin and Christopher Condon

Treasury Secretary Janet Yellen indicated the US will be unable to sign a treaty on global tax rules in time to uphold a deal that prevents other countries from imposing new levies on some of the largest American tech companies.

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Pillar 2, State Aid, and Industrial Policy

  • By Mindy Herzfeld

Mindy Herzfeld explains that the OECD will likely find itself policing a wider range of state subsidies as countries look for creative ways to shore up investment while staying on the right side of pillar 2.

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Tax Chiefs Vow to Deepen Cooperation on Global Minimum Tax Rules

  • By Stephanie Soong

Representatives of more than 40 members of the Forum on Tax Administration have pledged to facilitate the administration of global minimum tax rules by cooperating on compliance issues like risk assessment.

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Is the UTPR a 100 Percent Tax on a Deemed Distribution?

  • By Fadi Shaheen

Fadi Shaheen floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by the UTPR entity, and he addresses questions that would follow regarding the desirability of such a confiscatory tax and its interaction with tax treaties.

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OECD Treaty Under Global Tax Deal Faces Several Hurdles

  • By Michael Rapoport and Danish Mehboob

A variety of knotty issues remain over a multilateral treaty aimed at implementing a key part of the OECD’s global tax agreement—including disagreements among countries over withholding taxes and digital services taxes, and getting the US to sign on.

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Countries Advance Global Tax Reforms With Amount A Treaty Text

  • By Stephanie Soong

The OECD has published the text of a treaty providing for the reallocation of taxing rights to market jurisdictions and a digital tax repeal, but some details need resolution before countries can start signing it.

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Canada’s Digital Services Tax Sets the Stage for a US Trade War

  • By Jefferson Vanderwolk

Among the many perplexing questions raised by the OECD’s two-pillar project on global tax policy, one mystery is why the government of Canada has broken ranks with other major players in the Inclusive Framework on Base Erosion and Profit Shifting—by announcing its intention to proceed unilaterally with a digital services tax.

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It's Time to Act Against Canada's DST, U.S. Lawmakers Insist

  • By Amanda Athanasiou

U.S. Trade Representative Katherine Tai is facing increasing pressure from lawmakers to take decisive action against the impending enactment of Canada’s digital services tax as Senate Finance Committee members urge new warnings.

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Ireland to Raise R&D Credit Rate Amid Global Minimum Tax Rollout

  • By Danish Mehboob

Ireland’s latest budget proposes to increase the research and development credit for companies from 25% to 30% to maintain the value of investment amid a global rollout of a minimum tax framework.

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Wyden Calls on Tai to Tell Canada the US Will Fight Digital Tax

  • By Michael Bruning

Senate Finance Committee Chair Ron Wyden and Republican Mike Crapo ask US Trade Representative Katherine Tai to tell Canada that America will forcefully defend US companies against its digital services tax.

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This Country Won the Global Tax Game, and Is Swimming in Money

  • By Paul Hannon

On October 10, Ireland created a sovereign-wealth fund thanks to outsize profits from U.S. technology and pharmaceutical giants seeking to lower their tax bills. Ireland’s government said a new Future Ireland Fund could amass €100 billion by the middle of the next decade.

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Does Pillar 2 Provide a Windfall to Tax Havens?

  • By Martin A. Sullivan

Martin A. Sullivan shows how pillar 2 could result in a windfall for tax havens.

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Bermuda Mulls 15 Percent Corporate Tax Rate Aligned With Pillar 2

  • By Stephanie Soong

Bermuda is holding another consultation on its response to global minimum tax implementation, this time proposing a 15 percent corporate tax rate and qualified refundable tax credits to take effect in 2025.

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Trade Group Presses OECD for Better Pillar 2 Safe Harbors

  • By Stephanie Soong

A trade group is urging the OECD to improve its pillar 2 administrative guidance — including amending and adding safe harbors — to give affected businesses more certainty about how the global minimum tax rules will work.

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Pillar 1 Amount B: Simplifying the Arm's-Length Principle for Baseline Distribution Activities

  • By Lorraine Eden

In this article, Eden critiques the latest public consultation document for pillar 1 amount B and proposes options for increasing the likelihood of its adoption and success.

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Treasury Issues Rules on ‘Killer B’ Triangular Reorganizations

  • By Michael Rapoport

The Treasury Department and the IRS proposed regulations aimed at reining in “Killer B” triangular reorganizations involving foreign corporations, which the government says companies have used in the past to avoid taxes.

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Irish Corporate Tax Receipts Drop, Portending Growth Slowdown

  • By Sarah Paez

Irish corporate tax receipts have dropped two months in a row, with third-quarter revenues falling €700 million short of projections as researchers predict a slowing corporate tax take in line with modest economic growth.

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Countries Agree on Tool to Implement Global Tax Pact Rules

  • By Lauren Vella

The OECD announced Tuesday that countries involved in the global tax deal negotiations have agreed on a multilateral convention to implement a rule aimed at helping developing countries collect more tax under treaties that set low withholding rates.

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Germany, China Pledge to Help Administer Global Minimum Tax Rules

  • By Lauren Vella

Germany and China have pledged to help developing nations administer the global minimum tax rules just months before they’re poised to go into effect.

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Dutch Authorities Staffing Up for Global Tax Push, Minister Says

  • By Danish Mehboob

A top Dutch tax official said the Netherlands is preparing for the global minimum tax rollout and will support developing countries in international tax policymaking at the United Nations following talks with US tax officials.

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Singapore Plans Safe Harbor for Its Global Minimum Tax Legislation

  • By Natasha Teja

Singapore aims to roll out a safe harbor as part of its adoption of the global minimum tax rules, according to a top government official.

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Singapore Aiming for Pillar 2 Domestic Top-Up Tax Safe Harbor

  • By Stephanie Soong

Singapore will strive to implement a qualified domestic minimum top-up tax safe harbor to make tax compliance as easy as possible for companies affected by pillar 2 rules, according to a top government finance official.

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