2024

The International Fiscal Association Congress will this year be held in Africa. The timing is fortuitous, as African countries are making significant advances in both modernizing tax administration and pursuing economic growth.

While the adverse ruling is embarrassing, it’s only temporary. Ireland has a lot of credit in the bank following its moves to abolish the double Irish corporate tax avoidance structure and its embracing of both EU and global efforts to bring in a new set of global tax rules, which should maintain the country’s attractiveness to international investors.

Italy’s Investment Management Exemption regime will help foreign investment vehicles avoid PE risk and attract non-resident investors to Italy, say CMS practitioners.

House Republicans are voicing support for a US business group’s legal challenge of an EU directive requiring all bloc member states to apply global minimum tax rules and vowing retaliatory action if countries employ the levy on US companies.

The Organization for Economic Cooperation and Development forecasts “somewhere between 60 to 80 jurisdictions” to adopt the rules in the coming years, said John Peterson, head of division for cross-border and international tax at the organization.

Business leaders have warned that the UK government’s tax-raising plans and negativity about its economic inheritance risk undermining its efforts to boost private sector investment.

The Estonian government agreed in principle Tuesday to impose a 2% tax on accounting profits of companies and raise value-added tax to 24% in a bid to bolster the country’s security and defense, according to a press release from the country’s ministry of finance.

The new 15% global minimum tax that became effective in almost 40 countries is barely having an impact on many of the 100 largest US companies so far, but it has prompted low-tax jurisdictions to raise their corporate tax rates.

Companies in Singapore would receive generous tax credits to offset some of the impact of the global minimum tax under legislation being considered by lawmakers.

Apple has suffered a significant defeat after the EU’s top court ruled the iPhone maker must pay €13bn in back taxes, overturning an earlier decision in the Big Tech group’s favor.

By joining the international tax agreement, the US can move towards a stronger “country by country” minimum tax — which acts as a greater deterrent to tax competition and eliminates the perverse effects of global averaging across high and low tax jurisdictions.

Turkish lawmakers have drafted new tax proposals aimed mostly at companies, seeking to repair a budget buffeted by last year’s earthquakes, in what would be the biggest overhaul in a generation.

Norway’s planned clampdown on the nation’s wealthiest citizens is provoking a backlash from entrepreneurs who warn the measure will just worsen the economy’s heavy dependence on oil and gas.

In a communique at their summit in Italy, the G-7 leaders said they hope the treaty will be open for signature by the end of June, as OECD officials have said. The G-7 leaders also called for further progress on the implementation of the OECD’s global minimum tax.

Turkish Finance Minister Mehmet Simsek said the government has postponed plans to introduce a “very limited” transaction tax on stock trading, after push back from traders.

Sir Keir Starmer, UK opposition party leader, set out plans to raise £8.6bn in tax in the Labour manifesto on Thursday as he promised to “relight the fires” of economic growth and bring “Conservative chaos” to an end.

The Danish government presents a plan to significantly lower taxes for entrepreneurs, in a move to bolster the startup scene in the Nordic country, particularly in the biotech industry.

Saudi Arabia laid out a series of steps it plans to take to boost its debt capital market, including a possible easing in taxes it hopes will make local corporate bonds more appealing to foreign investors.

According to new research from Oxford university, the world’s largest private capital firms have avoided income taxes on more than $1tn in incentive fees since 2000 by structuring the payments in a way that subjected them to a much lower levy.

Canadian Conservative Leader Pierre Poilievre said he would vote against the government’s proposal to raise the capital gains tax inclusion rate, ending weeks of speculation about where he would land on the issue.

Digital services taxes would generate similar revenue for countries to those under the global minimum tax, according to research from an intergovernmental organization of developing countries.

A UN committee has provided countries with a preliminary document for negotiating a global tax treaty, naming fair taxation of corporations and wealth taxes as areas of focus.

A surprising tax change in agriculture powerhouse Brazil has the potential to make soy grown in the world’s largest bean exporter less competitive with supplies from the US, according to a report from risk management firm Amius Ltd.

A draft European Union law on transfer pricing may have the best chance of moving forward before the end of the year in what is likely to be a slow season for EU tax rulemaking.

The OECD missed its initial March deadline to finish talks on Pillar One and faces tough opposition in trying to get the agreement to the finish line by the end of June.

The International Compliance Assurance Program allows companies to preemptively discuss their transfer pricing positions with tax administrations to obtain more certainty about their tax bills.

A UK Treasury official reported substantial progress in ironing out differences over the global tax treaty, saying it is at a point where countries can work toward adopting it.

The European Union law ,meant to protect local industry from foreign undercutting in the transition to a greener economy, may do more harm than good by hindering the competitiveness of the EU industry and failing to reduce carbon dioxide emissions by the intended amount.

Business and trade groups that represent US-based multinationals with big Australian businesses are hearing concerns from members following the Australian Tax Office’s tough stance against multinationals they view as avoiding its taxes.  

Biden’s tariffs on $18 billion in Chinese electric vehicles, batteries and computer chips, announced last month, are likely too small to lift the economy’s overall price level, economists said. But Trump’s plan for 60 percent tariffs on all $427 billion in goods that China ships to the United States each year would almost certainly reshape trade in ways that consumers would notice.

Exchanges of information between tax authorities in Latin America brought in an additional 2.1 billion euros ($2.3 billion) in revenue over the last five years, and other transparency measures have allowed Latin American countries to identify at least 27.8 billion euros in additional revenue since 2009.

The Australian Budget released earlier this month had measures for multinational enterprises that ranged from barely a surprise to some game-changers from a tax administration perspective on transactions.

The 2024-2025 Australian federal budget released this month continues to balance inflationary pressures with cost-of-living concerns. In this environment, specific measures on royalty tax avoidance and foreign resident capital gains tax target multinationals and foreign investors in Australia.

A special committee of countries charged with creating draft terms for a global tax treaty on tax cooperation will start hashing out key details of the proposals’ shape and contents in the coming weeks, including how countries will eventually make decisions and what priority issues it will pursue.

Unfavorable treatment of the highly lucrative US R&D credit under the global minimum tax is threatening to expose American companies to higher taxes and prompting some to rethink new investments in the US.

Treasury Secretary Janet Yellen said the US won’t sign an agreement to finalize a still-pending global tax deal until India and China agree to key unresolved issues. Yellen told reports, “India, in particular, has been a holdout and China has not really engaged very much in these negotiations at all.”

While more than 140 countries have signed on to the global minimum tax agreement known as Pillar Two, these efforts don’t always have the backing of domestic legislative bodies, some of which have done little to adopt laws that would make Pillar Two effective.

One of the biggest questions about the global minimum tax agreement known as Pillar Two has been how different countries would implement it locally. In the US, Congress must consider the future of the domestic minimum tax on which Pillar Two is based—the Global Intangible Low Taxed Income regime, commonly known as GILTI—before the transition period to adopt the 15% tax ends in 2026.

Agreement on a few key issues under Amount B of the global tax rules has been elusive so far—such as which countries’ choice to use Amount B would be respected under the rules, which transfer pricing transactions would fall in scope, and whether the simplified rules should be optional or mandatory.

Italy has amended its global minimum tax law to include temporary key safe harbor provisions to simplify the application of the tax rules, while Belgium companies can now register for the tax.

The European Commission referred Spain to the EU Court of Justice Thursday for breaching rules on taxation in company mergers. The commission also said Germany, Hungary, Poland and Romania were infringing EU law by not sharing with other EU tax administrations data on earnings from trading via online platforms.

The European Commission is threatening to refer six countries—Poland, Portugal, Spain, Cyprus, Latvia and Lithuania—to the top European court unless they provide details of their implementation of the global minimum tax within two months.

To preserve tax fairness that underlies voluntary tax compliance, the OECD should leave room for facts-and-circumstances exceptions to part of its global tax treaty.

The global minimum tax is turning out to be a huge compliance hurdle for many multinationals, especially those with subsidiaries spread out in hundreds of cities across the globe. In order to pay their global minimum tax bill in a timely manner, large companies need to build new systems to synthesize thousands of pieces of new data and track the differences between countries’ local laws applying the levy.

The design of the global minimum tax is making large multinational companies vulnerable to disputes with countries all over the world—and halfway into 2024, there’s no tool to resolve them due to the differences in adoption of the global tax rules across jurisdictions.

US multinational companies are engaging in what essentially amounts to a political game of chicken, dissolving their overseas holding companies and reshoring ownership of their subsidiaries to delay paying the new 15% global minimum tax—perhaps indefinitely.

What once seemed like an impossibility, a global billionaire’s tax is now being considered by G20 finance ministers.

Australia plans to introduce a new tax penalty for big companies that try to avoid taxes on royalties in its latest move to crack down on multinationals that it says aren’t paying their fair share.

European Union finance ministers agreed in principle to a law intended to speed up cross-border withholding tax refund procedures and that will require EU countries to replace current tax refund systems for cross-border dividend and interest payments with improved, simpler procedures.

The Biden administration will increase tariffs from 25 percent to 100 percent on Chinese EV imports to offset Chinese export practices, which they argued “favor Chinese automakers at the expense of U.S. and other foreign automakers and autoworkers and are leading to a massive surge of unfairly underpriced Chinese vehicles into foreign markets.”