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Swedish Parliament Says EU BEFIT Proposal Breaches Subsidiarity

  • By Elodie Lamer

The European Commission’s Business in Europe: Framework for Income Taxation proposal to harmonize aspects of the corporate tax rules disproportionately encroaches on the competences of EU member states, the Swedish Riksdag (parliament) said.

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EU Corporate Sustainability Reporting Involves Tax Information

  • By Max Zanderink
  • By Vera Moll
  • By Bernard van Gerrevink

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

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Australian Tax Office Seeks Comment on Interest-Limitation Rules

  • By Michael Rapoport

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

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A New Global Tax Is About to Raise Billions. The U.S. Is Missing Out

  • By Richard Rubin, Jennifer Williams, and Paul Hannon

The 15% global minimum tax is here, and it is raising corporate tax payments—just not in the U.S., where Congress hasn’t changed tax law to conform with an international deal.

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Revisiting the Similarity Between CFC Rules and the IIR

  • By Lucas De Lima Carvalho

Lucas de Lima Carvalho considers that maybe the income inclusion rule isn’t so bad when it’s compared with the undertaxed payments rule.

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Amazon and the Future of State Aid Law in Direct Tax Matters

  • By Leopoldo Parada

Leopoldo Parada examines the Court of Justice of the European Union’s rejection of the European Commission’s use of an autonomous EU arm’s-length standard and the Court’s move to set limits on the use of the OECD transfer pricing guidelines to identify a selective advantage under EU state aid law in the Court’s recent Amazon decision.

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India Aims to Collect $4.3 Billion in Stock Trading Tax in FY25

  • By Chiranjivi Chakraborty

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

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Platform Contributions: More Than a Definition

  • By Ryan Finley

Ryan Finley explains why the cost-sharing regulations’ definition of “platform contribution” shouldn't be interpreted as a restriction on specified methods other than the income method.

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Australia Projects to Raise $243 Million From Global Minimum Tax

  • By Danish Mehboob

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.

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European Parliament Political Groups Draw Battle Lines on BEFIT

  • By Elodie Lamer

Some members of the European Parliament want the Business in Europe: Framework for Income Taxation proposal to include a formula for dividing the tax pie among EU member states.

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Pillar 2 and the United States: What’s Next

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah examines what’s next for the United States and U.S. multinationals as pillar 2 becomes a reality.

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Latvia to Delay Full Global Minimum Tax Roll Out Until 2029

  • By Jan Stojaspal

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.

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Is Treasury Failing Its Mandate to Protect Against Double Taxation?

  • By Mindy Herzfeld

Mindy Herzfeld examines whether Treasury’s recent efforts to clarify when U.S. taxpayers may claim a foreign tax credit contradicts U.S. law and congressional mandates.

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U.K. Diverted Profits Tax Yield Plummets by 80 Percent

  • By Alexander F. Peter

While transfer pricing revenues reverted to pre-pandemic figures at £1.6 billion, results from the diverted profits tax appear to be highly cyclical, yielding only £40 million in tax year 2022–2023, HM Revenue & Customs said.

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Australian Mining Group Backs Credits in Response to IRA

  • By Amanda Athanasiou

An Australian mining advocacy group has urged the commonwealth to adopt tax credits to contend with the movement of critical minerals investments to the United States as a result of the Inflation Reduction Act.

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The Quest for Tax Certainty: Improving Multilateral Dispute Resolution

  • By Michelle Markham

Michelle Markham examines the methods different countries are using to enhance tax certainty by exploring recent developments in multilateral avenues for improving international tax dispute resolution.

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OECD Tax Tool Assesses Risks Faster Than Other Instruments

  • By Lauren Vella
  • By Danish Mehboob

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.

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EU Starts Infringement Procedures Over Pillar 2 Implementation

  • By Stephanie Soong

Nine EU member states face infringement proceedings after missing a key deadline to communicate to the European Commission about measures transposing the pillar 2 global minimum tax directive into their national laws.

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EU Should Delay BEFIT Amid Global Tax Reforms, Businesses Say

  • By Stephanie Soong

The adoption of a proposed common EU corporate tax system should be delayed until pillar 2 rules are comprehensively implemented and pillar 1 talks are finalized, business groups told the European Commission.

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Effects From Moore: Does the Corporate Tax Require Realization?

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah explores the history of the corporate tax as an excise versus income tax and explains potential effects from the Moore and Altria cases.

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Score One for the Treaty Makers and One for the Treaty Shoppers: Canada’s Husky Energy Case

  • By Allison Christians

Allison Christians examines a recent Tax Court of Canada decision that took an unusual approach to treaty shopping.

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The Proposed Expansion of Foreign Currency Rules

  • By Carrie Brandon Elliot

Carrie Brandon Elliot reviews prop. reg. section 1.987-1(b), which addresses foreign currency gains and losses of foreign branches using functional currencies that differ from that of their owners.

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OECD Official Notes Issues With Capital Gains Tax Regimes

  • By Elodie Lamer

An OECD official told the European Parliament’s subcommittee on tax matters that the way capital gains are taxed in OECD countries could lead to tax minimization strategies, inequities, and the loss of revenues.

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Interest Limitation Violates EU Treaty, Swedish Court Says

  • By Alexander F. Peter

Sweden’s interest limitation rule that denies an interest deduction for a cross-border intercompany loan to finance an intragroup reorganization violates the freedom of establishment guaranteed by the EU treaty, a Swedish court has held.

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Revisiting an Age-Old Issue: What Taxes Should Be Treated as Income Taxes?

  • By Paul W. Oosterhuis

Paul W. Oosterhuis offers proposals for determining which taxes the multinational tax community can agree are properly imposed as income taxes and proposals for determining what taxes other countries should defer to, either through foreign tax credits or income exemptions.

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EU Council’s Belgian Presidency Wants Bloc to Lead on Pillar 1

  • By Elodie Lamer

Belgian Finance Minister Vincent Van Peteghem told members of the European Parliament that the EU needs to take the lead in the discussion regarding pillar 1 of the OECD’s global corporate tax plan.

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Stakeholders Question OECD’s Proposed 30-Day PE for Extractives

  • By Amanda Athanasiou

Extractives industry groups and other stakeholders have voiced concerns over a recent OECD proposal to amend the model tax convention commentary by including a 30-day permanent establishment threshold for natural resource extraction.

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Academics Unite in Call for EU Agency on Tax Cooperation

  • By Elodie Lamer

More than 100 tax academics from 17 EU member states are calling for the creation of an EU agency for tax cooperation to facilitate the exchange of information, particularly regarding VAT and excise taxes.

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Foreign Tax Credit Recapture and Schedule UTP

  • By Lee A. Sheppard

Lee A. Sheppard examines the foreign tax credit recapture and Schedule UTP aspects of Liberty Global and details why the Tax Court rejected Liberty Global’s argument that its capital gain in excess of its overall foreign loss should be exempt from U.S. tax.

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Treasury Considering Issuing Proposed Regs on Cloud Sourcing

  • By Andrew Velarde

Treasury is considering issuing proposed regs on sourcing rules for cloud transactions as companion regulations to finalized rules regarding characterization.

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What’s Next for the Committee-Passed Carbon Tariff Bill?

  • By Emma Dumain

Four Republicans broke with others in their party to back legislation that would study the greenhouse gas footprint of certain industrial imports and exports — something that could lead to the creation of new tariffs.

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Pepsico Appeals Australia Ruling for Tough Tax on Multinationals

  • By Michael Rapoport

Pepsico appeals a November court ruling that authorized use of the diverted profits tax, taxing company profits at a 40% rate, for the first time in Australia.  

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Rishi Sunak vows ‘more to come’ on pre-election tax cuts

  • By Fleming, Sam
  • By Jim Pickard
  • By George Parker

UK’s prime minister says the government has clear priorities to control spending and welfare, in order to lower people’s taxes.  

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Companies Snap Up New Clean-Energy Tax Credits

  • By Richard Rubin and Amrith Ramkumar

A new government program is designed to funnel cash quickly to renewable-energy developers, potentially accelerating the transition from fossil fuels.

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European People's Party Wants to Revive EU Digital Tax

  • By Jean Comte

The European People's Party is likely to push for an EU digital tax during the 2024 European elections, according to its draft manifesto obtained by Tax Notes.

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Why Did the IRS Win? A Remarkable Year in Tax Litigation, Part 2

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah continues his examination of 2023 legal victories for the government with a look at an offshore hedge fund case and a Tax Cuts and Jobs Act tax planning case.

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U.S. Stakeholders Call for DST Enforcement, Clarity, and More

  • By Nana Ama Sarfo

Nana Ama Sarfo reviews some comments received from the U.S. Treasury Department's consultation on pillar 1.

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EU Council’s Belgian Presidency Notes Pitfalls Posed by IRA

  • By Elodie Lamer

As Belgium takes over the EU Council presidency, Prime Minister Alexander De Croo is warning that the EU risks being squeezed between the United States — with its Inflation Reduction Act — and China.

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Taiwan Tax Fix Tucked Into Congress’s Tax Package Framework

  • By Cady Stanton

Taxwriters included a long-negotiated double taxation fix between the United States and Taiwan in the framework for a bipartisan, bicameral tax package deal, raising the chances for passage of the tax agreement this Congress.

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South Korea’s Yoon Calls for Bold Tax Changes to Boost Stocks

  • By Youkyung Lee

South Korea’s president and top financial regulator seeks to avoid excessive taxation that undermines the stock market and causes South Korean stocks to trade at a lower value.  

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Software Royalty Withholding Tax Rules Clarified by Australia

  • By Danish Mehboob

The Australian government’s new draft ruling details scenarios when payments for software will count as royalties and copyright that are liable for tax, based on case law and new examples of modern software distribution arrangements. The ruling is expected to apply to situations both before and after it is finalized. 

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Collaboration Is Gateway to Success Under New Global Tax Rules

  • By Ann-Maree Wolff

Ann-Maree Wolff of Business at OECD explains challenges of the new global minimum tax rules and what multinational enterprises and governments can do to successfully implement the new reporting system. 

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US Lawmakers Near Taiwan Tax Deal, Risking Anger From China

  • By Mackenzie Hawkins

A proposal by US lawmakers would reduce withholding taxes on qualified Taiwanese residents doing business in the US from 30% to 10% on interest and royalties, and down to 15% on most dividends.

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CAMT and CFC Dividends, Part 2

  • By Lee A. Sheppard

Lee A. Sheppard looks at a recent Treasury notice on compliance with the new corporate alternative minimum tax and discusses how the guidance is both stingy and generous.

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OECD Rulemaking, the APA, and Chevron Deference

  • By Mindy Herzfeld

Mindy Herzfeld examines the legal status of pillar 2 administrative guidance around the world and considers how administrative due process requirements might apply to OECD rulemaking.

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Disentangling the OECD’s New Estimates of Pillar 2 Effects

  • By Martin A. Sullivan

Martin A. Sullivan provides context for unraveling the bountiful statistics in a recent OECD report on the economic effects of pillar 2.

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Global Battery Race Heats Up With Billions for Europe’s Northvolt

  • By Amrith Ramkumar

Concerns about the world’s reliance on Chinese batteries and the climate law known as the Inflation Reduction Act are driving a global competition for investments from companies such as Northvolt.

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Growing income inequality is driving public mistrust

  • By Sandrine Dixson-Decleve

Governments can address economic inequality by raising funds and redistributing income and wealth through increases in tax progressivity, implementing wealth taxation measures, and enacting windfall taxation on extreme profits generated by corporations. 

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UN Experts Renew Charge That OECD Tax Pact Violates Human Rights

  • By Michael Rapoport

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. 

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New Philippine Finance Chief to Push Tax Bills, More Revenue

  • By Andreo Calonzo, Ditas Lopez, Cliff Venzon

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. 

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