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2023

Swiss Pillar 2 Tax Receipts May Fall Short of Projections

The 50 largest Swiss groups will pay nearly $300 million for the 2024 financial year in Switzerland and elsewhere, far less than government expectations, according to a Deloitte Switzerland study.

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Should the States Return to Worldwide Combined Reporting?

Reuven S. Avi-Yonah examines the history of worldwide combined reporting and its relevance today.

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German Coalition to Lower Corporate Taxes, Support Pillar 2

Germany’s mainstream political parties have pledged to cut corporate tax rates while supporting the OECD’s minimum tax plan as part of an agreement that lays out the framework for a governing coalition.

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South Korea Offsets U.S. Tariffs With Tax Breaks for Auto Sector

South Korea will introduce tax incentives for new car purchases and other measures to support the country’s automobile industry, which has been buffeted by sharply higher U.S. tariffs.

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GLOBE and the Excess Negative Tax

Lucas de Lima Carvalho explores the excess negative tax introduced in the model rules, which raises concerns about ability to pay and whether jurisdictions can tax “income” that constituent entities did not earn in the relevant fiscal year.

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A Shifting Landscape: International Taxation of Software Payments

Giammarco Cottani and Nadia C. Altenburg explain the necessity for international consistency regarding taxation of software to avoid an escalating rift between technology-exporting and technology-importing countries.

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U.S. Tariffs Solidify MEPs’ Stance on EU Competition Rules

Members of the European Parliament said EU competition rules are not a bargaining chip to avoid U.S. tariffs and that companies structured through tax havens should be barred from receiving state aid.

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Using Tariffs to Make Canada a State? It’s Been Tried Before

Joseph J. Thorndike examines how the United States, since the earliest days of its nationhood, has attempted to use tariffs to pressure Canada into becoming a U.S. state.

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BusinessEurope Asks EU to Reassess Its Position on Pillar 2

Advocacy group BusinessEurope urged the EU to consider the United States’ disengagement from the OECD’s global tax plan to ensure that the bloc’s pillar 2 implementation doesn’t expose its businesses to "geopolitical and economic retaliation."

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Trump’s Tariffs Generate Tons of Criticism as Uncertainty Abounds

Economists and trade groups alike are concerned that the uncertainty produced by Trump’s new round of tariffs will create trade barriers and detrimentally affect consumers.

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Automation of Transfer Pricing Analysis Beyond Amount B

Kerem Yener Toklu proposes an approach to estimate the distribution of returns for a tested party based on its entity- and market-specific factors, enabling the identification and statistical testing of economically significant risks while capturing the risk-return tradeoff.

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How to Simplify New Cloud Computing Regs for Greater Taxpayer Certainty

Paul Poliakov explains the key features of proposed cloud computing transaction regulations and suggests how to simplify the rules to promote taxpayer certainty and reduce compliance problems.

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More Countries Decline to Adopt Amount B Framework

The Spanish government has published in its official gazette regulations that implement its global minimum tax regime, covering administrative issues including tax calculations, information return filing, and penalties.

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CARICOM to Update Multilateral Tax Treaty

Caribbean Community (CARICOM) officials have finalized a protocol to the 1994 CARICOM income tax treaty that would align the agreement with international standards for information exchange and dispute resolution, according to a March 31 release published on the CARICOM website.

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USTR Identifies EU Countries With Taxes That Hamper Trade

The Office of the U.S. Trade Representative has cataloged EU countries' taxes that it considers trade barriers hindering U.S. exporters in a report published ahead of President Trump's self-declared “Liberation Day.”

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NTUF Says Trump Should Push for End to Digital Services Taxes

President Trump should stop negotiating with the OECD on the global tax deal but could continue talks to eliminate digital services taxes, but he should leave negotiations if United States interests aren’t addressed, the National Taxpayers Union Foundation said in a March 28 report.

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Tariffs, Trade, and Transfer Pricing: A Guide to Navigating Economic Uncertainty

Wes Cornwell, Ana María Romero, and Kirsten Speas examine the rise of tariffs in international trade and explain their effect on typical manufacturing models across four sectors of the economy.

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Branch Currency Rules Invalid

Lee A. Sheppard examines regulations on the determination of taxable income or loss and foreign currency gain or loss regarding a qualified business unit.

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International Tax Wish List, Part 2: Addressing Subpart F and GILTI

In Part 2 of a series, Mindy Herzfeld suggests substantive changes to international tax rules necessitated by the Tax Cuts and Jobs Act and later global tax developments, including pre-TCJA provisions that need revision and TCJA law changes not functioning as intended.

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Post-Loper, IRS Has Its Eye on Transportation Case

The IRS is highlighting a Department of Transportation appellate court decision as an “interesting” development following the elimination of Chevron deference, as debate swirls over reg writing authority based on a general rulemaking statute.

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U.N. Convention Could Address Cross-Border Digital Tax Issues

A U.N. framework convention for international tax cooperation could address solutions for the taxation of cross-border digital services, including withholding taxes on technical services.

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A Reciprocal VAT?

Reuven S. Avi-Yonah examines President Trump’s “Fair and Reciprocal Plan” to impose reciprocal tariffs.

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Litigating Trump’s Tariffs, Part 1: The Lessons of Yoshida

In Part 1 of a two-part series, Robert Goulder comments on the ability of U.S. taxpayers to challenge tariffs in federal court.

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EU Groups Propose Pillar 2 Permanent Safe Harbor Features

BusinessEurope and Accountancy Europe have told the Platform for Good Tax Governance that a new OECD global minimum tax permanent safe harbor should be designed without the “once out, always out” rule to ensure its effectiveness.

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EU Lets U.S. Territories Off the Hook on BEPS

American Samoa, Guam, and the Virgin Islands won't have to implement the base erosion and profit-shifting project minimum standards to be removed from the EU's list of noncooperative jurisdictions.

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Revitalizing the U.S. Semiconductor Supply Chain Through Tax Policy

Patrick M. Ryle, Caleb S. Watkins, Keith Carruthers, and Robert Haverland examine the final regulations on the advanced manufacturing investment credit, focusing on the direct-pay election, the denial of the double benefit rule, and the excessive payment rule.

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Reeves Hints at U.S. Tariff Pressure Regarding U.K. DST

U.K. Chancellor of the Exchequer Rachel Reeves indicated the digital services tax is part of tariff discussions with the U.S. government but dodged questions about whether she is under pressure to drop it.

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No Amount B in Austria’s Detailed Transfer Pricing Rules Update

A comprehensive revision of Austria’s transfer pricing guidelines presents rule changes as mere clarifications despite their partially retroactive tightening effect, while simultaneously omitting any guidance on the OECD’s amount B concept.

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Cloud Services Sourcing Regulations: Moving in the Right Direction?

Paul W. Oosterhuis, Will Shirey, and Moshe A. Gershenfeld analyze a recently proposed method for determining the source of income for international cloud transactions that are characterized as services for sourcing purposes, arguing that the proposed regulations can help achieve certainty for global businesses.

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Does Transfer Pricing Have a Loper Bright Problem?

Thomas D. Bettge, Mark R. Martin, and Hans Gerling consider how the Supreme Court’s decision in Loper Bright may affect the application of section 482, the first sentence of which serves as the basis for the entire U.S. transfer pricing system but does not squarely address one of Loper Bright’s guardrails — the question of delegation.

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Harmonizing Tax Frontiers: OECD’s Soft Law in International Taxation and Its Effect on the EU Legal Order

Franklin Cachia explores the role of OECD soft law in shaping international taxation within the EU legal order, emphasizing its dual effect on harmonization and national sovereignty.

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Australian Government Will Tax Digital Assets Under Existing Laws

The Australian government will not introduce new tax legislation focused on cryptoassets, but will continue to evaluate the need for decentralized finance rules following the Board of Taxation's recommendations.

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OECD Fails to Respond to Shifting Political and Economic Winds

Jefferson Vanderwolk challenges the OECD’s still positive approach to the two-pillar project despite recent roadblocks.

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Ireland Announces Tax Revenue Analysis Amid U.S. Tariffs

 The Ireland Department of Finance issued a release announcing the publication of an Irish tax revenue analysis in relation to the widespread U.S. tariff policies, noting that the paper does not take into account windfall corporate tax receipts from the last few fiscal years, which could mean that the need to protect Irish public finances is higher than the paper estimates.

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Revisiting U.S. Transfer Pricing Disputes Using OECD Guidance

Ryan Finley explains why the OECD transfer pricing guidelines corroborate some of the more controversial interpretations of the U.S. regulations.

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Trump, Gold Cards, and Taxes: Wooing the Huddled Masses

Robert Goulder comments on replacement of the EB-5 visa program with a residency-for-sale scheme.

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Tax on Ultrarich Is Gaining Support at All Levels in the EU

The Netherlands has asked the EU Code of Conduct Group on business taxation to set its sights on the tax treatment of wealthy individuals while the EU Tax Observatory sees its own tax proposal gaining traction.

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EU Drops DEBRA in Final Savings and Investments Union Plan

The European Commission removed a plea for member states to drop opposition to the Debt-Equity Bias Reduction Allowance directive in its new savings and investments union plan.

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U.S. Coalition Supports Withdrawal From OECD’s Global Tax Plan

The Alliance for Competitive Taxation issued a letter to U.S. Treasury Secretary Scott Bessent voicing support for the executive order pulling the United States out of the OECD global tax deal, emphasizing that the undertaxed profits rule under pillar 2 of the OECD’s two-pillar tax reform plan would cause the United States to lose an estimated $122 billion in tax revenue over the next decade.

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EU Tax Commissioner Against Throwing Pillar 2 ‘in the Dustbin’

As some EU member states and businesses ratchet up the pressure to put pillar 2 on pause amid global tax and trade tensions, EU Tax Commissioner Wopke Hoekstra said the bloc should stand its ground.

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IRS Memo on CWI: Moving Away From the Arm’s-Length Standard

Michael McDonald analyzes whether a recent IRS generic legal advice memorandum affects the way the commensurate with income standard should be implemented compared with former guidance.

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Canadian Tariffs and Cross-Border Taxes: Opportunity for a Reset

Mindy Herzfeld explains how recent U.S. tariff policy could be an opportunity for a reset of Canada’s tax policies toward U.S. multinationals.

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EU Transfer Pricing Platform Talks Collapse

The European Commission is not interested in establishing a coordinating group on transfer pricing that does not produce political commitment from member states or peer reviews, leaving talks on a joint platform at an impasse.

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Is the UTPR Extraterritorial or Discriminatory?

Reuven S. Avi-Yonah explains the relationship between recent executive orders and the Defending American Jobs and Investment Act with the debate over discriminatory international taxes.

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The Trump Memoranda and the Future of International Taxation

Raffaele Russo and Gaia Maglione examine the future of international taxation following the withdrawal of support for the OECD global tax deal and the launching of the America First trade policy via Trump administration memoranda.

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EU to Target Republican States’ Products With Countertariffs

After the Trump administration’s decision to impose a 25 percent import duty on steel and aluminum, the EU plans to hit the U.S. president where it hurts, targeting Republican states with tariffs on their exports.

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Tax Platform Will Soon Finalize Tax Incentives Principles

The Platform for Collaboration on Tax hopes to finalize in the coming weeks incentives principles to guide policymakers navigating an international landscape shaped by developments such as the OECD’s global minimum tax rules.

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The Sword Against Discriminatory Foreign Taxes Is a Bit Rusty

Libin Zhang examines section 891 and how it is limited by withholding tax statutes and U.S. income tax treaties.

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Latin America and the Caribbean’s Rise in Tax Cooperation

Nana Ama Sarfo reviews the first year of the Regional Platform for Tax Cooperation in Latin America and the Caribbean.

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EU Walking Tightrope Between OECD and U.S. Minimum Tax Rules

Despite EU businesses’ increasing calls for a pause in pillar 2 talks, a senior EU official said the bloc will seek an agreement that considers both the U.S. and OECD rules on minimum corporate taxation.

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