2023

The IRS and Treasury are contemplating the proper attribution method to determine the source of income for cloud transactions and are questioning how to evaluate relevant factors like intangible property.

Patrick Driessen argues that the similarity between the U.S. base erosion and antiabuse tax and digital services taxes undermines the United States’ criticism of DSTs.

Adam Kern analyzes how treating global intangible low-taxed income as an income inclusion rule will affect the stability of pillar 2.

The OECD on July 17 published a report — prepared ahead of the July 17-18 meeting of G20 finance ministers and central bank governors in South Africa — regarding recent developments in international tax cooperation, including its support of various G20 priorities such as tax transparency and the implementation of the base erosion and profit-shifting minimum standards.

The OECD plans to adapt its transfer pricing guidelines to new realities like global mobility and artificial intelligence and to develop a common understanding of terms that are often disputed, an official said.

The lines between tax and trade policy are likely to become increasingly blurred as the Trump administration shifts its attention to disarming overseas digital services taxes, observers say.

The U.N. tax framework convention’s early protocol on services should incorporate fractional apportionment or formulary apportionment similar to amount A of pillar 1 of the OECD’s two-pillar global tax reform plan, the G24 said.

The design of an own resource to finance the EU budget as a contribution levied on high-turnover companies raises legal questions.

Pramod Kumar Siva and William H. Byrnes explain why the UTPR, formerly known as the undertaxed profits rule, is an unlawful extraterritorial tax that contravenes legal norms, generates economic distortions, and diminishes international tax cooperation.

A new Eurobarometer shows that 80 percent of Europeans polled want large multinational enterprises to pay a minimum amount of tax in each of their countries of operation, an idea that finds a majority in all member states.

Muhammad Ashfaq Ahmed examines changes to the U.N. Model Tax Convention 2025 from their genesis, evolution, and development, to their finalization, approval, and future implications from both an international tax law and international political economy perspective.

Mindy Herzfeld examines the developments that led to the recent G7 agreement to respect the U.S. tax regime as “a side-by-side system” with the OECD’s pillar 2 and what that means for the future of digital services taxes and tax multilateralism more broadly.

The EU has “a quite negative view” on the United States' proposal to credit its minimum tax rules when calculating their qualified domestic minimum top-up taxes under pillar 2, according to a top European Commission official.

In a letter to the editor, Jefferson VanderWolk argues that pillar 2 should be abandoned rather than an attempt be made to salvage it.

Nana Ama Sarfo discusses Nigeria's new tax reform legislation and its emphasis on base broadening and tax enforcement.

Robert Goulder comments on the recent G7 agreement regarding pillar 2 and the withdrawal of proposed section 899.

Governments across the globe breathed a sigh of relief when Republicans dropped section 899, but slow progress on the terms of the deal reached by the G7 could see it return with a vengeance.

Germany’s economy minister has rejected the idea of imposing a digital tax on U.S. technology companies that the minister of state for culture had said the government was drafting in May.

Irish Finance Minister Paschal Donohoe said there are still outstanding questions about how the G7 deal on pillar 2 will affect competition between the EU and the United States and the future of the law.

The European People’s Party's advocate for copyright issues in the European Parliament has suggested a 7 percent levy on artificial intelligence companies that use copyright-protected works to compensate rightsholders.

BRICS member states said they support work on a U.N. tax convention and its role in promoting better cooperation and transparency to address issues like illicit financial flows and tax evasion by the superrich.

Simone Decè considers whether implementing a global wealth tax is practical, analyzing the challenges that different proposed solutions present.

Martin A. Sullivan examines the foreign-derived deduction-eligible income provision in the reconciliation bill.

Several high-income countries and civil society groups committed to improving developing countries' domestic tax systems to increase revenue collection there at a major U.N. development financing conference.

Lucas de Lima Carvalho examines the status of the OECD’s multilateral instrument in Argentina and Peru.

Nana Ama Sarfo reviews the tax-related provisions of the outcome document from the U.N.'s Fourth Financing for Development Conference and the Sevilla Platform for Action.

 Foreign investors that reinvest their dividends from Chinese entities into qualifying domestic companies will be allowed a 10 percent tax credit, the government announced June 30.

Shafi U. Khan Niazi and Richard Krever examine how the European Commission attempted to stop intra-Europe transfer pricing schemes by reversing private rulings that facilitated profit shifting through preferential tax treatment in the profit destination jurisdictions.

The European Commission says the G7 provisional agreement on pillar 2 is based on a permanent safe harbor shielding U.S. firms, but the lack of details leaves stakeholders drawing various conclusions.

The U.N. committee negotiating a framework convention on international tax cooperation will focus on the fair allocation of taxing rights — especially over multinationals — and the prevention and resolution of tax disputes at its next sessions.

Guy A. Bracuti examines President Trump’s Executive Order 14269, “Restoring America’s Maritime Dominance,” and the tax provisions of the Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025.

The United States’ G7 counterparts have agreed to not apply their pillar 2 global anti-base-erosion (GLOBE) rules to U.S.-parented groups, but those companies would still be in scope of qualified domestic minimum top-up taxes.

Canada will rescind its digital services tax as part of its efforts to continue trade negotiations with the United States, Canadian Prime Minister Mark Carney said June 29.

HM Revenue & Customs welcomed the removal of the section 899 revenge tax in the U.S. One Big Beautiful Bill Act (H.R. 1), adding it hopes to publish new U.K. pillar 2 guidance in July.

Wei Cui argues that the One Big Beautiful Bill Act’s formerly proposed section 899, targeting “unfair” foreign taxes, was more sensible than many observers initially perceived, and that, if seen as a restrained deployment of U.S. market power, it represented a defensible and ultimately acceptable approach for addressing the undertaxed profits rule and digital services taxes.

Mindy Herzfeld examines the changes made by the Senate to some provisions of the One Big Beautiful Bill Act, saying that the Senate’s version of the bill improves on the retaliatory tax measures introduced by the House and would simplify and improve the U.S. international tax regime.

The Chinese government has issued a decree regulating tax-related information that internet platform companies are required to submit.

Stephen L. Curtis continues his analysis of PayPal’s cost-sharing arrangement, explains how the cost-sharing regulations can be exploited to possibly shift billions in U.S. profits offshore with little or no IRS detection or enforcement, and explores how the agency’s position could be changing.

Employees are increasingly on the move in the wake of the COVID-19 pandemic, and observers say the OECD is well placed to design templates to make it easier for countries, companies, and employees to determine tax residency.

Raffaele Petruzzi and Argyro Myzithra explore the implications of remote working arrangements for a multinational enterprise's permanent establishment and its transfer pricing issues.

EU finance ministers adopted a progress report on tax issues and deleted several of its points on pillar 2 of the global tax deal, including the need for its implementation worldwide.

Senate Republicans addressed key concerns about the scope of a proposed excise tax on remittances in their version of the reconciliation tax bill, but the overarching policy still has its detractors.

A portion of the ‘one, big, beautiful bill’ could lead to a new tax on foreigners’ U.S. investments in private equity and credit. Some of them are treading cautiously.

Robert Goulder comments on the practice of duty drawbacks and a recent legislative proposal to limit their reach.

A loophole in Trump’s policy bill would continue to encourage offshoring.

Senate Republicans unveiled a robust set of international corporate tax reforms in their version of the reconciliation tax bill, including adjustments to the House-passed version and a suite of new provisions.

Members of the European Parliament rejected a report calling for a strong U.N. tax process in the context of the next international conference on financing development, though that specific provision was consensual.

U.N. countries agreed to prioritize international tax cooperation ahead of a major development financing conference, with an emphasis on improving domestic resource mobilization for developing countries.

 Oliver R. Hoor explains the relationship between taxation and inflation.

The EU Council's Polish presidency urged the European Commission to revise its plan to fund the bloc's budget after member states pushed back on the current package of proposed levies yet again.