2023

The OECD has published a manual for countries interested in adopting multilateral approaches to mutual agreement procedures and advance pricing agreements, in a bid to improve certainty for taxpayers and tax administrations alike.

Economiesuisse is voting to have Switzerland implement global minimum taxation rules under the OECD-brokered, two-pillar plan for modernizing the international corporation tax architecture for the 21st century. Switzerland is currently debating whether to adopt global minimum tax rules, but the referendum will take place in June.

Austria collected 43 million euros from the tax in 2020 and 80 million in 2021. The government predicts the tax will bring in 120 million euros in 2023, the statement said. Austria's tax went into effect in 2020 and is meant to be "an interim solution until a global consensus is reached," the statement said

The EU is preparing to issue a document on a temporary crisis and transition framework in response to the Green Energy Tax Credits in the IRA. The European Commission will issue a proposal to make the framework "broader and more comprehensive" or to simply "convert" it into a crisis and transition framework. The EU wants to increase the thresholds of their regulation to allow member states more leeway in designing aid that fits their national needs, like, a temporary response to the IRA to boost the sectors of the green transition which are at risk of relocating, in order to lure and retain companies.

On February 2, 2023, the Organisation for Economic Co-operation and Development (OECD) described how the U.S. tax system will interact with the minimum taxes being implemented in other countries. These rules provide U.S. companies with a partial reprieve through 2025. This new guidance spelled out how the existing 10.5% minimum tax on U.S. companies' foreign income interacts with other countries' new taxes. However, other countries will only be so tolerant of the U.S.'s delayed implementation. In addition, U.S. lawmakers are increasingly hesitant about a coordinated global corporate tax increase because of the possibility that such an increase will primarily affect U.S. companies. The United States will need to figure out what can be done to alleviate these concerns before 2025.

The Inflation Reduction Act, signed into law in August 2022, provided tax credits and other support for clean-energy projects. Concerned that these subsidies will draw investment away from Europe, the European Union (EU) wants to provide tax breaks and other aid to clean-tech companies. The EU's proposed response said that state-aid rules could be loosened to make it easier for governments to back new investment in clean-tech production facilities, including through tax breaks.

This Editorial considers the current approach of keeping the unanimity rule for the making of tax legislation in Europe, while at the same time consistently exploring alternative pathways to circumvent it. It argues that this approach is a reflection of the trade-off between (perceived) national tax sovereignty on one hand, and tax efficiency and fairness on the other hand.

The article analyzes strategies that low-income countries and high-income countries might undertake in response to the GloBE rules on the assumption that are indeed implemented by a critical mass of countries.

Baistrocchi explores Global tax hubs which he describes as the black boxes of the international tax regime. The paper offers the theory of global tax hubs as an intermediation market. It argues that tax hubs are the matchmakers of the international tax regime.

Heinemann and Stiller analyze the impact of the widely introduced e-invoicing in Italy on cross-border value-added tax fraud. They calculate trade gaps based on product flows on the most detailed level between Italy and the remaining countries of the European Union with results suggesting a significant decline in cross-border fraud in response to the introduction of mandatory e-invoicing, providing an important rationale for the application of this measure by other countries.

This paper provides a high-level overview of Pillar Two Global Minimum Tax in terms of its policy objectives, technical design and implications for Canada. After teasing out some significant known and unknown challenges, it offers some thoughts on whether, and if so, how and when Canada can proceed with implementation.

Navarro’s paper is aimed at depicting the rather asymmetrical state of affairs on the access to dispute resolution remedies in instances of tax abuse. It also purports to demonstrate that there are compelling policy reasons to support granting access to both mutual agreement and arbitration procedures in these cases and to criticize the incoherencies that originate from the existing restrictions.