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Remaining Tax Treaties Face Strong Head Winds
By Jad Chamseddine
The Senate Foreign Relations Committee chair hopes the Senatewill approve more tax treaties this year, but he expects delays.
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New Tax Commissioner Vows to Use TFEU to End Tax Unanimity
By Elodie Lamer
The incoming EU tax commissioner has promised to use the controversial article 116 of the Treaty on the Functioning of the European Union to circumvent the EU Council's unanimity rule in taxation.
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France Proposes €1 Billion Corporate Tax Cut, Drawing Criticism
By Stephanie Soong Johnston
France's draft 2020 budget proposed billions in tax cuts, including a ÔøΩ1 billion decrease for companies, but it did not impress some business groups,which said itwas unlikely to boost competitiveness and investment.
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The BEAT of Fashion: Anticipating the Final Rules
By Lee A. Sheppard
Lee A. Sheppard previews the upcoming final BEAT regulations and predicts some of the changes that might be made to the proposed guidance.
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The GILTI High-Tax Exception: The Good, the Bad, and the Ugly
By Chetan Vagholkar and Eric Horvitz
In this article, the authors summarize some good, bad, and ugly results of making the global intangible low-taxed income high-tax exception election under the proposed regulations.
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EU Members Divided Over Scope of Corporate Tax Reform Proposals
ByJoe Kirwin
European Union member countries are divided overwhether the bloc's proposals for a common corporate tax base and new anti-tax abuse provisionswould apply to all companies or only to large multinationals.
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Internet Giants Threatened With Forced Disclosure in France
By Helene Fouquet
France's former digital affairs ministerwants to force internet giants like Amazon, Alphabet, Microsoft, Facebook and Apple to reveal how much profit they make in France, saying the companies are understating their French activities to a vast extent.
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OECD lays foundation for fairer taxing rights
Proposals from the OECD, a forum for research and debate among mostly rich countries, provide a promising basis for a new model. Theywould give governments a "tax right" over the profits of consumer-facing businesses depending on the share of saleswithin their territory.
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OECD Base Erosion Tax Faces Info-Sharing Hurdles
An under-the-radar proposal from the Organization for Economic Cooperation and Development to stem income shifting could require a new degree of information sharing, something experts saywould be either a difficult obstacle or a new chapter in theworld's shift toward tax transparency. The OECD's proposal, part of its sweeping digital tax project, is similar to the 2017 U.S. base erosion and anti-abuse tax andwould aim to reduce deductions on payments meant to shift income out of a jurisdiction. But, unlike the BEAT, itwould hinge on a calculation of how much the payment is taxed in the receiving jurisdiction.
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Netherlands Planning Slower But Deeper Corporate Tax Cut
On September 17, 2019, Dutch State Secretary for Finance Menno Snel presented the Government's 2020 Tax Plan to the House of Representatives. It includes revised plans for corporate tax cuts. Under legislation approved in December 2018, the rate of corporate tax on income exceeding EUR200,000 (USD221,000)was due to fall from 25 percent to 22.55 percent in 2020 and to 20.5 percent in 2021. However, under the new proposals, corporate tax above this thresholdwill remain at 25 percent next year, before falling to 21.7 percent in 2021.
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Chilean government introduces important changes to proposed tax on digital services
Sandra Benedetto and Fernando Binder analyse several amendments made by the Chilean government to the Tax Bill submitted to Congress in August last year, one ofwhich seeks to tax digital serviceswith value added tax (VAT).
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How could the TMT industry respond to digital tax proposals?
The technology, media and telecommunications (TMT) sector may be directly affected by the G20/OECD digital economy tax proposals. Sajeev Sidher and Kaidi Liu of Deloitte Tax LLP look at the uncertainties ahead.
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EU court rules in favour of Starbucks, but against Fiat over state aid
Starbucks haswon its case against the European Commission's 2015 state aid decision today, but the EC clawed back awin against Fiat Chrysler in two conflicting cases over the use of the transactional net margin method.
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Brazil's tax reform proposals have greatest chance of success
Taxpayers and advisors say Brazil's proposal to overhaul the multiple indirect tax regimes and rates into a single system have a good chance of succeeding because of the need for simpler tax rules. But progresswill be slow.
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U.S. CEOs Urge OECD to Give GILTI-Paying Firms a Break
By Stephanie Soong Johnsto
The Tax Cuts and Jobs Act's global intangible low-taxed income provision must be treated as a compliant minimum tax in any OECD proposal to adapt international tax rules to the digital age, CEOs said.
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U.S. Nonprofit Urges OECD to Stick to Tax Principles
By Tax Analyst
The Business Roundtable, a nonprofit U.S. organization, urged the Organization for Economic Cooperation and Development to continue to oppose double taxation, promote effective dispute resolution, and minimize changes to profit allocation and rules on the right to tax,while they are considered as international tax rule changes.
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OECD Must Preserve Transfer Pricing Regime, Irish Official Says
By Ryan Finley
Although Ireland does not oppose the OECD's efforts to modernize the international tax system, the government believes that the existing transfer pricing framework must be preserved, according to Irish Minister for Finance Paschal Donohoe.
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Ireland Issues Overview of Position in GCEU Apple State Aid Case
By Tax Analyst
In a September 17 overview of a General Court of the European Union hearing of a case regarding the European Commission's 2016 decision finding Ireland granted illegal state aid to Apple Sales International and Apple Operations Europe, Ireland's Department of Finance noted that they are contesting the decision on the basis that they have not given favorable tax treatment or granted state aid to Apple or its subsidiaries.
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Netherlands Presents 2020 Tax Plan
By Tax Analyst
The Dutch government introduced its 2020 tax plan on September 17, outlining implementation of a national climate agreement, income tax and VAT cuts, and a corporation tax rate increase.
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New EU Tax Commissioner Supports Digital Tax
By Teri Sprackland
If an international agreement on digital taxation is not reached next year, the next European Commissionwill propose a Europeanweb tax, the incoming EU tax commissioner said.
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Liberal Democrats Condemn U.K. Corporation Tax Cut
By Andrew Goodall
Reducing U.K. corporation tax to 17 percent in 2020 is a stupid policy that has had no impact on investment decisions, according to Susan Kramer, Liberal Democrat Treasury spokeswoman in the House of Lords.
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Carbon Taxes Worldwide Too Low to Change Behavior, OECD Finds
By Isabel Gottlieb
Theworld's biggest polluting countries aren't doing enough to tax carbon consumption and encourage cleaner energy, an OECD report found.
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Drop Plans to Cut Corporate Tax, Dutch Opposition Urges
By Linda Thompson
Dutch opposition lawmakers are pressing the government to abandon plans to cut the headline corporate tax rate by almost four percentage points in 2021.
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EU Attacks Apple's Phantom Menace, Draws Irish Ire in Tax Clash (1)
By Aoifewhite and Stephanie Bodoni
Apple Inc. and Ireland's court room clashwith the European Commission finally lived up to its billing as theworld's biggest tax case.
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Klobuchar Presses Treasury on Companies Offshoring Operations
By Siri Bulusu
Sen. Amy Klobuchar has asked Treasury if it is taking steps to block companies from offshoring jobs because of tax incentives.
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Why a wealth tax is capitalism's handmaiden
Taxing capital holdings boosts rewards for investingwell.
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Apple Can't Win Its $14 Billion European Tax Battle
Apple 's ÔøΩ13 billion ($14.4 billion) tax fightwith Europe is grinding through the courts. It could end up generating unwelcome headlinesÔøΩfor Apple and Brussels alike.whatwas a story about the European Union hittingwhat it sees as an undertaxed technology giant has turned into a tussle for billions in tax revenue between Brussels andwashington. The shift is awkward for European officials,who are seeking to avoid a tradewarwith President Trump.
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Taxpayers eye the advantages of Italy's patent box reform
Italian taxpayers evaluate the benefits of a new option in the patent box regime allowing companies to make autonomous calculations of tax benefits.
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India Cuts Corporate Taxes to Counter Slowing Growth
The Indian government on Friday announced a slew of concessions aimed at boosting the economy thatwill reduce most corporate taxes for local companies to about 25% from 30%. Finance Minister Nirmala Sitharaman said the lower tax rateswill retroactively apply from April 1, the beginning of India's fiscal year.
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Carbon Border Tax Goes on EU Finance Ministers" to-Consider List
By Joe Kirwin
European Union finance ministers meeting in Helskini agreed to consider adopting a carbon border tax on imports coming from countries that didn't commit to the Paris Agreement.
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German Finance Minister Backs Global Minimum Tax
By Hamza Ali
A global minimum tax thatwill ensure tech giants "pay their fair share" is on the horizon, Germany's finance minister Olaf Scholz said in at meeting in Finland.
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Labour to Expand U.K.'s Financial Transaction Tax If Elected
By Jessica Shankleman
The opposition Labour Partywould seek to expand a tax on financial transactions if it is elected to government, according to the party's Treasury spokesman John McDonnell.
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Google Gets EU Court Boost in Fight Over Hungary Advertising Tax (1)
By Stephanie Bodoni
Google got a boost in a tax case at the European Union's top court that's made the search-engine giant an unlikely ally of EU antitrust chief Margrethe Vestager in a clashwith Hungary.
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Mexico Presses Further on Taxing Tech With 2020 Budget Proposal
By Andrea Navarro
Mexico's tax collectors are taking a big step in their bid to get a piece of the booming digital economy pie.
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OECD to Rank Countries on Resolving Tax Disputes
By Joe Stanley-Smith
The OECDwill for the first time rank countries on how effectively they negotiate to resolve tax disputes, a top tax official from the organization said.
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U.S. Will Use Trade Powers to Deter Unilateral Digital Taxes
By Siri Bulusu and Hamza Ali
Up to 24 governments could be in the firing line of punishing U.S. trade policies if they go aheadwith their individual digital tax plans, a senior U.S. Treasury officialwarned.
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Expect OECD Digital Tax Plan in October√¢$But Not Impact Report
By Isabel Gottlieb
Fresh details on the OECD's digital tax projectwill be out early October, but a full analysis of its impact on countries' revenueswon't be ready this year, the group's tax chief said.
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Targeting Specific Industries Won't Solve Digital Tax: U.S. Official (1)
By Hamza Ali
The U.S. Treasury has urged the OECD not to narrowly focus on industries like social media in its recommendations to reform theway countries tax the digital economy.
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Apple has day in court over Irish tax bill
By Patrick McGee and Javier Espinoza
The iPhone's appeal to its ÔøΩ13bn fine is heard sameweek as its latest product launch.
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Preliminary Estimates of the Likely Actual Revenue Effects of the TCJA's Provisions
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.
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Group Hysteria: How the Dutch Are Agonizing Over the Future of the Fiscal Unity
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.
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Brazil's Road to OECD Accession: Tax Transparency and BEPS Standards
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.
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OECD Highlights Taxpayer Morale as a Major Factor in Compliance
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.
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OECD Should Abandon Focus on Residual Profit, Group Argues
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.
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High Excess Profits Threshold May Be Appropriate, Harter Says
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.
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Toward a 21st-Century International Tax Regime
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.
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Unilateral Actions to Tax Digital Now Diluted, OECD Chief Says
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.
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Lawmakers Ask Mnuchin, Rettig for Plans to Discourage Offshoring
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."
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Dutch Government to Reform Business Tax Rules​
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.
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Google Pays France Over $1 Billion to Settle Tax Case
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."