2024

The US is looking at consistent implementation of the global minimum tax rules across countries through a peer review process to ensure its foreign tax credit can be distributed appropriately to companies in regimes that qualify under the review.

Ireland wants to circumscribe its incoming corporate tax break for dividend income to tax treaty countries in the latest “strawman” version of the proposal with scope and administration details.

A top Dutch tax official suggested tweaks to the country’s corporation tax to replace the higher bank tax and upcoming dividend tax on stock buybacks.

Acting Deputy Assistant Secretary for International Affairs at the Treasury, Scott Levine, said the US should adopt an income inclusion rule or reform its current global intangible low-taxed income rule, known as GILTI, so that it is compliant with the global minimum tax rules and provides more tax certainty to corporations.

Ignacio Gepp, lawyer at Puente Sur, assess Latin America’s use of AI in tax administration and potential consequences to taxpayer rights.

Pressure from EU and recent international tax developments have led Switzerland to align its national tax system with new international standards by focusing on transfer pricing provisions.

Norway may have breached state aid rules by granting carbon tax exemptions for some waste incineration and some industrial uses of natural gas and liquefied petroleum gas, the authority that oversees Norway’s compliance with European Union single market rules said.

The OECD continues negotiations over the global tax treaty, after missing a March 31 deadline to agree on the convention’s final text. Issues that remain unresolved include withholding taxes and the definition of digital service taxes.

UK start-ups and small businesses have accused HM Revenue & Customs of putting economic growth and innovation at risk by rejecting legitimate claims for research and development tax relief, delaying payments and clawing back credits. The result has left companies exploring options to move overseas or scrapping plans to create jobs or invest.

New Zealand finalized a law that will introduce the global minimum corporate income tax of 15%, via an income inclusion rule and an undertaxed profits rule. The income inclusion rule will apply to New Zealand-headquartered multinationals, and the undertaxed profits rule will apply a top-up tax on foreign companies that operate in New Zealand but are taxed below 15% in their home jurisdictions.

The OECD is considering using one of its existing tools to provide taxpayers the ability to gain more certainty about their positions if they are subject to the global minimum tax and other provisions under the global tax deal.

The first customs duties on digital products such as online films and software downloads will hit consumers and businesses in 2026, increasing prices in some countries, the head of the World Trade Organization has predicted. 

China filed a complaint to the World Trade Organization alleging the US’ Inflation Reduction Act and associated rules are “discriminatory” and have “seriously distorted” the global EV supply chain by blocking electric-vehicle manufacturers from sourcing materials from China and other foreign adversaries.

The law aims to ease the burden of taxation and bureaucracy to strengthen the country’s competitiveness as a business location, with Europe’s biggest economy struggling to generate growth.

The Netherlands is recommending that work on the United Nations tax treaty meet sustainable development goals and be consistent with the Organization for Economic Cooperation and Development’s tax work without duplicating it.

Italian Finance Minister Giancarlo Giorgetti told the country’s Chamber of Deputies on Wednesday that signing the Organization for Economic Cooperation and Development’s treaty looks problematic because of the political dynamics in some large countries, including the US, that are crucial to finalizing the deal.

The UK government aims to introduce its carbon border tax on Jan. 1, 2027, and is seeking feedback on its design, implementation, and administration—including the scope of products and ways to calculate emissions.

The EU commission says rules on voting procedures do not need to be changed, but EU countries could agree to activate a procedure allowed by the rules under which a unanimous decision could be taken to permit qualified majority decisions in some areas currently subject to unanimity, including tax.

The United Arab Emirates is consulting on the global minimum tax framework, including policy options for the extraterritorial rules. The UAE wants feedback on how the framework interacts with the country’s new corporate tax system and implementation of rules which ensure the top-up tax is collected on foreign in-scope entities too.

Australia should exempt multinational companies from reporting tax information from each country where they have operations if they’re not required to report it at home, tax and accounting firms told the Treasury department.

If companies make transfer pricing adjustments after the end of the year, as many do, they could be disqualified from using a safe harbor that simplifies the global minimum tax’s calculations and reduces their tax liabilities.

France started offering its green industry tax credit to companies to offset costs up to €350 million ($381 million) per qualified investment in energy. The tax credit is expected to generate €23 billion in investments, create 40,000 jobs, and cut 35 million tons of CO2 emissions by 2030.

Developing countries laying out recommendations for a new framework convention at the United Nations are seeking protocols to address the taxation of digital services, environmental taxes, exchange of information for both services and wealth, and illicit financial flows.

Tax authorities in Africa and Ukraine said technical assistance from the OECD in transfer pricing has resulted in higher revenue and improved compliance.

Pierce O’Reilly, head of business and international taxes at the Organization for Economic Cooperation and Development, noted that the minimum tax’s substance-based income exclusion rule will continue to support investment into low-capacity countries that tend to offer significant corporate investments.

Low-capacity jurisdictions may not benefit from the OECD’s optional framework to simplify transfer pricing for some business transactions, because of a lack of data and administrative resources available to determine the revenue companies owe from such transfer pricing.

Spotify Premium subscribers in France will soon get a price increase due to additional costs on music streaming services imposed by the government, as part of the CNM Tax, the company says in a statement.

Dubai, the Middle East’s financial hub, issued a decision to impose a 20% annual levy on the taxable income of foreign banks not based in the emirate’s international financial center.

US Republican lawmakers say the OECD’s multilateral tax treaty produces a loss of revenue to other countries, including China, and express concern the treaty is not effective to curb the proliferation of digital services taxes.

The UK government will abolish the non-dom tax status and replace it with a "modern, simpler and fairer residency-based system," Chancellor of the Exchequer Jeremy Hunt says in an effort to raise tax revenues.

The UK proposed a variety of tax breaks for small businesses in its Spring 2024 budget released Wednesday, along with plans to curb tax avoidance, implement reporting rules for crypto assets and new measures to regulate tax advisors.

Senior Economist for The Tax Foundation says the UN should prioritize harmonization, reducing complexity, and cross-border investment to increase international tax cooperation.

The EU’s carbon border adjustment mechanism taxes carbon-intensive imports to prevent a flood of cheap imports from countries with highly polluting industries, but only a fraction of EU companies expected to report emissions did so by an early deadline.

Chancellor of the Exchequer Jeremy Hunt has considered scrapping Britain’s non-domiciled tax, which allows about 70,000 people to avoid paying tax on their overseas earnings.

Covington’s Lauren Ann Ross analyzes advantages of the OECD International Compliance Assurance Program compared with advance pricing agreements and audit adjustments.

The OECD is on track to finish its multilateral tax treaty to reallocate taxing rights by March, and the global minimum tax will start in more than 35 countries this year. Estimates provide the treaty will reallocate $200 billion per year and increase revenues by at least $155 billion annually.

European Commission enforcement of Pillar Two rules for EU nations creates implementation challenges for countries and multinationals, PwC’s Will Morris, Giorgia Maffini, and Steven Kohart say.

Canada defended plans to enact a digital services tax against a potential economic reckoning from the US on Thursday, pointing to Washington’s tolerance for similar measures elsewhere.

Gabriel Zucman, who helped Elizabeth Warren develop a wealth tax plan for her 2020 US presidential campaign, is promoting a proposal for a global minimum wealth tax aimed at international coordination to tax the rich and fight poverty.

A group representing West African tax administrations is concerned the OECD’s recently published guidance on transfer pricing rules lack a definition for low-capacity jurisdictions and qualitative scoping criteria.

The OECD is considering developing a multilateral convention to resolve disputes related to the application of the global minimum tax, a top official for the organization said.

Implementation of the OECD’s global tax treaty is stalling due to political opposition in the US and tax negotiations by the UN influenced by developing nations.

 A tax deduction on interest in both the US and Singapore effectively lowers after-tax borrowing costs on bonds issued in Singapore.

The OECD’s latest report to simplify transfer pricing is complex and fails to confirm certain provisions, Imke Gerdes and Richard Fletcher of Baker McKenzie say.

New Zealand will not adopt the Organization for Economic Development’s new transfer pricing rules for bringing goods into the country, and instead continue to rely on its own rules.

The government is facing dissatisfaction over its ongoing efforts to end a payroll tax exemption as it aims to boost revenues and achieve its zero-deficit target for 2024. The Finance Ministry and Congress are trying to reach a deal to give companies more time to adapt to full taxation.

Estonia is allowed a six-year deferral of the obligation to implement the 15% tax OECD Global Minimum Tax because it has fewer than 12 companies that would be in scope.