2023

The OECD has released a package of pre-application templates to assist multinational groups with their international compliance assurance program applications, which must contain specific information and overviews of transactions.

The OECD is already eyeing other pressing profit attribution issues, including those related to global mobility, now that only minor items for a mandatory amount B still need to be negotiated, an OECD official has said.

A corporate proposal for a permanent country-by-country reporting safe harbor under the pillar 2 global anti-base-erosion rules could help make the EU more business friendly, according to a European Commission official.

The OECD is working on identifying jurisdictions that are planning on adopting the optional amount B transfer pricing simplification framework and will likely release a list in October, an OECD official said.

The European Commission’s tax decluttering and pro-competitiveness agenda will probably enhance its business-friendly image and build a bridge between pillar 2 and the anti-tax-avoidance directive, an EU official said.

Multinational enterprises may have reduced their base erosion and profit-shifting activity in the past few years, but the practice is still ongoing, according to the most recent country-by-country reporting data.

Three multinational music streaming companies have mounted a challenge to a Canadian streaming services tax in federal court, according to a digital music advocacy group that claims the levy is bad policy.

The European Parliament’s political groups have decided that a member of the Left Group will succeed Paul Tang as chair of the EP’s subcommittee on tax matters.

Hong Kong’s government has gazetted legislation establishing a patent box granting preferential tax treatment for qualifying income from intellectual property and IT.

In this symposium paper, the UF Tax Incubator working group examines the U.S. approach to taxing income earned through foreign branches, and it explores ongoing issues and potential reforms.

Business groups are sounding the alarm on potential trade and economic damage from Canada’s digital services tax following the issuance of a coming-into-force order by the Canadian government.

Robert Goulder comments on the new EU tariffs directed at Chinese EVs.

The view that low taxation increases investment is evolving, according to the European Commission, raising the question whether corporate tax can influence EU countries' competitiveness.

Netflix, Walt Disney, and other U.S. streaming companies have asked a Canadian court to stop plans by authorities to force them to fork over 5% of their sales in the country to finance local broadcast news and other domestic content.

Canada authorized the implementation of a digital-services tax, a move that threatens to trigger trade retaliation from Congress and the Biden administration.

Nana Ama Sarfo reviews the latest research commissioned by the South Centre, African Union, African Tax Administration Forum, and West African Tax Administration Forum into the amount of revenue developing countries might raise from amount A versus a digital services tax.

Introducing a global minimum tax rate for the largest multinational enterprises is a “catastrophic failure” because it burdens businesses and dampens EU competitiveness, according to Hungarian Prime Minister Viktor Orbán.

The end-of-June deadline for countries to conclude pillar 1 tax reform negotiations has come and gone, but delegates are still making good headway toward a final agreement, the OECD’s tax director said.

India has joined the group of countries that have extended the “unilateral measures compromise” with the United States that outlines a transitional approach to their digital services taxes before pillar 1 rules are implemented.

Nathan Boidman, Michael N. Kandev, and Marc André Gaudreau Duval, in the first installment of a two-part analysis, provide an overview of, and context for, the Global Minimum Tax Act — legislation now moving through Canada’s Parliament to implement pillar 2. Part two will more closely examine certain aspects of the legislation with a focus on provisions that yield interpretational issues or deal with antiavoidance.

Hafiz Choudhury explains efforts at the U.N. to foster an international taxation cooperation process more inclusive of developing countries. The opinions expressed in this article are solely those of the author and do not reflect the views of any other person or organization, in particular the U.N.

Aditi Goyal and Kanupriya Sharma explore the concept of “virtual permanent establishment” as a framework for taxation in an increasingly digital world, using the Clifford Chance case in India as a primary example.

More OECD focus on developing permanent safe harbors for pillar 2 minimum tax rules could decrease the need and volume of administrative guidance going forward, according to an OECD tax official.

High-income countries should engage constructively in U.N. discussions to develop a framework convention on international tax cooperation or risk a global spread of tension in tax policymaking, a top EU tax official said.

The U.S. is set on making Amount B, which deals with companies’ marketing and distribution activities, mandatory even as several other countries are pushing to make it optional.

The Canadian Parliament has passed a highly controversial 3 percent digital services tax on large businesses, sparking calls from U.S. trade groups for Canada to reconsider.

Policymakers have spent more than a decade crafting an international consensus on the allocation of corporate tax revenue, but the scattered landscape for settling tax cases could undermine the goal of a smoothly operating system.

The dispute, which was closely watched by experts, involved a one-time foreign income tax, but many saw it as a broader challenge to pre-emptively block Congress from passing a wealth tax.

The court rejected a challenge from conservative activists to a one-time tax on certain foreign investments but left unresolved questions about whether some leading Democratic revenue-raising ideas are constitutional.

Mindy Herzfeld examines what countries are doing to maintain competitiveness as pillar 2 makes offering fiscal incentives a fraught undertaking.

The leaders of the G7 countries are aiming to open the pillar 1 multilateral convention for signature by the end of June.

Young Ran (Christine) Kim with Cardozo School of Law and Darien Shanske with the University of California, Davis, continue their argument that a digital barter tax is a good idea and examine possible legal arguments and challenges.

The European Commission has added fair and efficient taxation, cross-border taxation, and double nontaxation to its renewed Platform for Good Tax Governance and is accepting applications for membership to its new expert group.

A coalition of technology and industry associations with business ties to Canada asked the Office of the U.S. Trade Representative to initiate a formal trade dispute in an effort to block Ottawa’s digital services tax.

A new U.N. framework convention could include high-level commitments on the fair allocation of taxing rights among countries, including the taxation of multinational enterprises and high-net-worth individuals.

Around a third of large U.S. multinational enterprises will be required to publish more disaggregated financial information than previously mandated in light of new EU public country-by-country reporting rules.

The Treasury Department is running into some complex disagreements over a global tax deal forged by the OECD as the end-of-June deadline to get a treaty ready for signature looms.

House Republicans hoping to extend the 2017 tax cuts are beginning to systematically examine tax provisions in the Democrats' landmark climate law.

The European Commission has informed stakeholders that it will soon begin an evaluation of the anti-tax-avoidance directive, especially how it would work alongside pillar 2 of the OECD’s global tax plan.

Malaysia’s 2024 budget tax incentives will benefit companies operating there, but if it wants to keep attracting investment after implementing global minimum tax rules in 2025, it must adopt further breaks, according to a new analysis.

Najeeb Memon breaks down the global issue of how royalty income from intangibles is taxed and provides suggestions on how to close the fairness gap.

While the deleterious consequences of failing to limit global warming are becoming more costly, doubt has been cast on the relevance of the presumed efficiency of carbon pricing relative to green tax breaks and subsidies.

House Republican appropriators kept their word on their intent to roll back funding to the OECD in fiscal 2025 appropriations as part of a larger protest against U.S. participation in the organization’s global tax deal negotiations.

Lee A. Sheppard examines the proposed share buyback excise tax regulations and related industry feedback, and she argues that the regulations overreach and should be withdrawn.

Mindy Herzfeld puzzles over the Biden administration’s opposition to a global minimum tax on the world’s richest people, touted as building on the success of the global corporate minimum tax.

Ahead of the U.K. general election, the Liberal Democrat Party has pledged to triple the digital services tax and freeze VAT, while the Green Party and Reform UK also outlined their tax plans.

The Bahamian government is set to introduce draft legislation for a qualified domestic minimum top-up tax that will likely apply retroactively to January 1, according to Prime Minister and Minister of Finance Philip Davis.

Jurisdictions in the OECD inclusive framework on base erosion and profit shifting are close to finalizing pillar 1 of a sweeping two-pillar global tax reform plan, according to an update from the group’s co-chairs.

Turkey is getting ready to introduce OECD-brokered global minimum tax rules to protect its right to tax in-scope multinational enterprises operating within its borders, according to Turkish Finance Minister Memhet Şimşek.

Jefferson VanderWolk cautions the international business community and developed countries not to ignore the international tax reform efforts underway at the United Nations and explains how these initiatives reveal important factors in global economic growth and what developing countries think about their taxing rights.