2019

Reform of the "uneconomical, unsustainable, and frankly unintelligible" business rates system in England cannot come soon enough, John Allan, president of the Confederation of British Industry (CBI), intends to tell business leaders.

In this article, the author continues his consideration of the approaches that New Zealand and Fiji have taken to the taxation of remote sales of services, focusing on how Fiji's technology could improve New Zealand's statutory approach to threshold rules, remote enforcement, and double taxation.

The Polish Ministry of Finance has released for public consultation draft tax guidance for the intellectual property box that came into effect January 1. The consultationwill close May 10.

Ireland's Department of Finance has announced the new consultations on tax incentives for the small and medium-size enterprise sector, capital gains tax entrepreneur relief, and the new incentive for employee stock options.

The Court of Appeal for Saskatchewan held that Canada's Parliament had legislative authority to enact the Greenhouse Gas Pollution Pricing Act (GGPPA), but Saskatchewan's premier says the fight is not over.

The European Commission believes Luxembourg's rulings granted to subsidiaries of Huhtamäki Oyj approving deemed interest deductions on interest-free debt appear to unilaterally reduce a multinational group's tax base despite the absence of double taxation risk.

Nana Ama Sarfo outlines the changing landscape of transfer pricing discussed at a recent NYU/KPMG tax symposium.

Martin A. Sullivan argues thatwhen it comes to the future of international income taxation, all roads lead to a minimum tax.

In an April 29 letter to Senate Foreign Relations Committee Chair James E. Risch, R-Idaho, and Senate Majority Leader Mitch McConnell, R-Ky., a group of companies called for swift action on the bilateral income tax treaties and protocols pending before the committee, noting that such treaties help foster trade and investment and protect U.S. businesses from double taxation.

OECD-led efforts to adapt international tax rules for the digital agewould benefit from more involvement from tech companies, especially if they arewilling to discusswhere they create their value, Denmark's tax minister said.

In this article, the authors discuss the IRS's most recent annual statutory report on advance pricing agreements.

Invigorated by its success in the recent parliamentary elections, the governing Partido Socialista Obrero Español (PSOE) is looking for legislative support for its plans to increase taxes by ÔøΩ5.65 billion a year.

The Information Technology Industry Council, adding to prior comments, has requested further relief for the treatment of research and experimentation expenses, such as not allocating or apportioning R&E expenses to the global intangible low-taxed income basket under reg. section 904(d)(1)(A), particularlywhen using the sales method.

Multinational tobacco giant British American Tobacco PLC's aggressive tax planning schemeswill deprive developing countries of an estimated $700 million in tax revenue from 2018 through 2030, according to a Tax Justice Network report.

The U.N. Subcommittee on Environmental Taxation Issues announced that it intends to create a handbookwith recommendations and practical advice on environmental taxation for developing countries.

Ireland has launched its triennial review of the tax credit designed to encourage research and development investment in the country.

The Austrian government has announced awide-ranging set of proposals to lower taxes by ÔøΩ6.5 billion annually, including a reduction in the corporate tax rate from 25 percent to 21 percent by 2023.

In a survey of business executives published on April 30 by Miller & Chevalier Chtd. and the National Foreign Trade Council, 31 percent of respondents said theywant to see further IRS guidance on global intangible low-taxed income, 29 percentwant guidance on the base erosion and anti-abuse tax, and 28 percentwant guidance on the section 163(j) limitation on business interest.

Business executives have little faith that Congresswill pass new tax laws this year, but they hope Treasury and the IRSwill produce more guidance on global intangible low-taxed income and the base erosion and antiabuse tax.

Keeping up and complyingwith the many changeswrought by the Tax Cuts and Jobs Act in the international tax arena this filing seasonwas a slog for many tax professionals.

The April 16 draft from the German Federal Ministry of Financewould implement European Council Directive 2017/1852,which provides for a mechanism to address tax treaty disputes among EU member states that meets the Action 14 minimum standard set by the Organization for Economic Cooperation and Development's tax base erosion and profit shifting project.

The digital revolution has transformed business models, entire economies and the lives of people around the globe. It has also tested the concept of traditional corporate tax rules, designed largely in the first half of the 20th century. These rules are now unfit for our increasingly digitalized and globalizedworld.

Germany looks set to introduce an economy-wide system of carbon emissions pricing after senior officials from both parties of Berlin's governing coalition reached a consensus on the proposal, the Frankfurter Allgemeine reported on Sunday.

The top two Democratic leaders on Monday told President Trump that any bipartisan infrastructure package needs to take into consideration climate change and include "substantial, new and real revenue" ÔøΩ a preview of the coming fight over tax hikes.

A reported Israeli plan for a digital services tax could provide a sounder basis for taxing multinational groups than previous attempts that relied on permanent establishment arguments or claims the groups are subject to VAT.

Facebook is paying more taxes in France as its operations there grow, and itwill also pay the country's digital services tax, according to Laurent Solly, chief of the company's French unit.

Roiled international relationships aren't disturbing the existing relationships between tax administrators in different countries, according to two top IRS enforcement officials.

A patchwork of partial agreements pertaining to specific types of transactions likelywould not attract international consensus on restructuring the international tax system, according to a U.S. Treasury official.

The U.K. branch of Taxwatch has called on the European Commission to investigate Google for their implementation of a tax avoidance scheme "which uses payments between companies located in two European states in order to avoid paying billions of euros in taxes to European Union countries every year" in their letter to EU Competition Commissioner Margrethe Vestager.

Canada's complicated tax system continues to burden taxpayers and governmentswith compliance and administrative costs, according to a study by the Fraser Institute.

Luxembourg's parliament has passed the 2019 budget, confirming a corporate tax rate cut and a more flexible interest expense limitation for consolidated corporate groups in linewith the 2016 EU anti-tax-avoidance directive (ATAD).

This article provides a detailed and structured synthesis of the discussion that took place in the context of the "fireside chat" event held by thewU Global Tax Policy Center at the Institute of Austrian and International Tax Law on December 17, 2018, atwhich Hellersteinwas the guest speaker. The eventwas one of the initiatives of the Digital Economy Tax Network, a multi-stakeholder forum,which organized aworkshop on the VAT/goods and services tax and the digital economy December 17-18, 2018, in Vienna.

Mindy Herzfeld describes debates about corporate taxes andwhether multinationals pay their fair share, focusing on recent legislative, business, and academic contributions.

The Manitoban government has decided to take legal action against the federal government's carbon tax, claiming that itwas unconstitutionally enforced since the province had created its own plan.

An appeals court has upheld a 2017 decision by a lower court that Google Ireland Ltd. did not have a permanent establishment in France based on activities performed by Google France.

An opportunity to reallocate global taxing rights and introduce a minimum corporate tax rate is upon us, and it may be the OECD's last chance to prove itself, according to the Tax Justice Network.

Neither territoriality nor freedom of establishment require an exemption from the United Kingdom's controlled foreign company regime for intragroup financing profitwhen the significant people functions take place domestically, according to the European Commission.

For a long time, Ireland has used taxes to aggressively attract incoming investment. Now this strategy is being questioned.

French President Emmanuel Macron announced tax cuts for middle-classworkers and plans for a more representative parliament Thursday as part of a promised response to theweekly yellow vest protests that damaged his presidency.

In this article, the author discusses the proposed U.S. foreign-derived intangible income regulations and highlights important areas that the regs clarify for taxpayers.

After reviewing Ireland's energy policies, the International Energy Agency (IEA) has recommended that the country implement an automatic increase of its carbon taxes to deter sectors from failing to meet their predetermined emissions limit.

Policymakers should continue the rapid global trend toward tax transparency by embracing public country-by-country reporting for multinationals across all industry sectors, according to a report by the Financial Accountability and Corporate Transparency (FACT) Coalition.

States that have incorporated the international provisions of the federal Tax Cuts and Jobs Act into their tax base could be challenged in court, according to practitioners.

Multistate Tax Commission general counsel Helen Hecht on April 24 floated the idea that states trying to tax global intangible low-taxed income deem as their base the amount of federal tax actually due on GILTI.