2024

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.

Thierry Viu of CMS France explains how the new finance bill strengthens the powers of the tax authorities in transfer pricing audits and what this means for international groups.

India is seeking to end a freeze on countries taxing electronic trade, a move that would allow tariffs to be imposed on anything from software downloads to video games.

Companies told Ireland’s finance ministry to broaden its proposal to exempt dividends from corporation tax to include the profits of foreign branches of Irish companies too, a move to draw more business operations to the country with a global minimum tax in place.

Countries involved in the OECD’s project to reduce base erosion and profit shifting determined the tax regimes in Hong Kong and the United Arab Emirates aren’t harmful, according to an update from the organization released Tuesday.

Under Chile’s 19% digital services tax, foreign companies providing digital services to clients in Chile voluntarily register with the tax authority and pay sales tax. Those that don’t are subject to a withholding tax for services provided to Chilean residents.

The EU’s new Corporate Sustainability Reporting Directive will have tax implications on those companies required to report.

The Australian Tax Office is soliciting feedback on proposed rules that would limit the amount of interest payments that multinational companies can deduct.

After raising tax on stock options, India projects to collect 12.5% more in security transaction tax in 2025.

The country expects to generate A$160 million in fiscal year 2025-26 and A$210 million in fiscal year 2026-27 from the 15% tax on Australian multinational parent and subsidiary companies with at least 750 million euros in annual global revenue.

As a country with only a handful of ultimate parent entities of groups that qualify for minimum taxation, Latvia is allowed a deferral of full European Union rules ensuring a global minimum level of taxation for multinational groups and large national groups.

Companies using the International Compliance Assurance Program assessed risks faster than with other legal tools and were able to obtain more certainty about their tax bills.

The 2021 global tax agreement could have “a discriminatory impact” by hurting predominantly non-white nations’ ability to collect taxes and pay for vital services for their people, according to nine experts who have been appointed by the UN Human Rights Council to report and advise on human rights issues. 

Philippine Finance Secretary, Ralph Recto, pledged to focus on boosting tax collection and sustaining current spending as he took over the job on Friday in the first revamp of President Ferdinand Marcos Jr.’s economic team since he assumed power in 2022. 

New international tax rules will force multinational companies to pay an extra 6.5% to 8.1% in tax, according to the OECD. The impact will be felt most acutely by companies that use tax havens, euphemistically known as investment hubs. 

After soliciting public feedback on the OECD’s multilateral tax treaty in case any important issues were missed, the US does not plan to reopen negotiations of the document, according to a Treasury Department official. However, some consideration as to the definition of terms in the treaty may be made.

The Treasury Department is focused on finding a “principled” way to deal with novel extraterritorial taxes like digital services taxes as it considers changes to its foreign tax credit rules. 

Countries categorized as “investment hubs”, such as Ireland and the Netherlands, will have the largest expected gains from the reforms, with corporate income tax revenues rising from 14 per cent minimum to up to 34 per cent. 

Following President Gustavo Petro’s calls for a lower corporate tax rate, Colombia’s finance minister said the government is revising a proposal to gradually reduce the corporate tax rate from 35% to 30% in the coming years.