Tax Concessions Undermine Pillar 2 Tax Rules, EU Study Says
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.
NGOs Criticize EU's Reluctance to Join a U.N. Tax Convention
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.
Multilateralism Crisis Mustn't Spread to Tax, Colombian Adviser Says
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.
European Parliament Report Addresses Excess Profits, Inflation
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.
Bipartisan Taiwan Tax Bill Text Issued by Congress’s Tax Writers
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.
Delegates Push Back on U.N. Work on Pillar 2 and Tax Incentives
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.
Nigeria Files Resolution to Work Toward UN Global Tax Convention
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.
Works on Pillar 1 Convention Issues to Run Into 2024, Yellen Says
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.
US to Miss Deadline to Avoid Fresh Digital Taxes, Yellen Says
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.
Tax Chiefs Vow to Deepen Cooperation on Global Minimum Tax Rules
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.
Is the UTPR a 100 Percent Tax on a Deemed Distribution?
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.
OECD Treaty Under Global Tax Deal Faces Several Hurdles
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.
Countries Advance Global Tax Reforms With Amount A Treaty Text
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.
Canada’s Digital Services Tax Sets the Stage for a US Trade War
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.
It's Time to Act Against Canada's DST, U.S. Lawmakers Insist
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.
Ireland to Raise R&D Credit Rate Amid Global Minimum Tax Rollout
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.
Wyden Calls on Tai to Tell Canada the US Will Fight Digital Tax
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.
This Country Won the Global Tax Game, and Is Swimming in Money
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.
Bermuda Mulls 15 Percent Corporate Tax Rate Aligned With Pillar 2
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.
Trade Group Presses OECD for Better Pillar 2 Safe Harbors
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.
Treasury Issues Rules on ‘Killer B’ Triangular Reorganizations
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.
Irish Corporate Tax Receipts Drop, Portending Growth Slowdown
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.
Countries Agree on Tool to Implement Global Tax Pact Rules
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.
Dutch Authorities Staffing Up for Global Tax Push, Minister Says
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.
Singapore Aiming for Pillar 2 Domestic Top-Up Tax Safe Harbor
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.
Limits in US-Taiwan Tax Relief Bill Differ From a Typical Treaty
The United States-Taiwan Expedited Double-Tax Relief Act, which is advancing to the full Senate, would provide an array of tax benefits on certain income earned by qualified residents of Taiwan from US investments or activities.
U.K. Updates Draft Pillar 2 Amendments With Safe Harbors
The United Kingdom has published more draft measures revising its pillar 2 legislation to reflect safe harbors and other features of the OECD’s latest administrative guidance for the global anti-base-erosion rules.
Hungary Makes Moves Toward Global Minimum Tax Adoption
Hungary’s finance minister has started talks with large Hungarian companies about ensuring the country remains competitive as it prepares draft legislation in the fall for transposing the EU’s global minimum tax directive into domestic law.
Deputy U.S. Trade Rep Presses Canada on Digital Tax Plan
The Office of the U.S. Trade Representative has again pushed back against Canada’s plans to introduce a digital services tax, days after American lawmakers warned that the tax, if imposed, might damage Canada-U.S. trade relations.
Global Carbon Pricing Challenge Gains New Members at U.N. Summit
Government officials from Norway and Denmark announced that their countries are joining the Canadian-led global carbon pricing challenge and emphasized the importance of international cooperation on carbon taxes to effectively reduce emissions.
U.S. Issues Final Rules to Keep Chip Funds Out of China
The Biden administration on September 22 issued final rules that would prohibit chip companies vying for a new infusion of federal cash from carrying out certain business expansions, partnerships and research in China, in what it described as an effort to protect United States national security.
Plowgian to U.N.: Don't Torpedo Global Tax Deal
A senior Treasury official has cautioned against efforts by the U.N. to pursue a separate multinational tax agreement, arguing that it would fundamentally undermine the progress made by the OECD’s inclusive framework.
World Leaders Call on UN to Start Developing Global Tax Norms
Several world leaders at a United Nations high-level panel said that the OECD is not the preferred organization to lead the international tax cooperation agenda, but existing work should not be duplicated.