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Int'l Tax News

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UN Eyes Two Components of Tax Framework, Aims For August Meeting

  • By Shefali Anand

The United Nations’ framework for international tax cooperation is likely to initially include tackling illicit financial flows and cross-border services, two key areas of concern for developing countries, a UN official said.

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U.S. Multinationals Are Becoming Less Multinational

  • By Martin A. Sullivan

Martin A. Sullivan uses new Bureau of Economic Analysis data on U.S. multinational foreign activities for a more detailed perspective now that some of the worst effects of the recent pandemic have subsided.

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QDMTTs: Pillar 2’s Minimum Tax Trendsetter

  • By Mindy Herzfeld

Mindy Herzfeld checks in on how countries are using and customizing qualified domestic minimum top-up taxes to meet their pillar 2 goals.

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Puerto Rico Seeks Global Minimum Tax Consulting Services

  • By Stephanie Soong

Puerto Rico’s Treasury Department is looking for international tax consulting services related to potential implementation of global minimum tax rules under pillar 2 of an OECD-brokered, two-pillar global tax reform plan.

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Saudi Arabia’s Tax Reforms Aim to Attract Foreign Investors

  • By Ahmed Altawyan

The Kingdom of Saudi Arabia is aiming to transform into a significant business hub, attracting a growing influx of foreign companies.

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US Sets Limits on Chinese Content to Receive EV Tax Credits

  • By Joe Deaux, Gabrielle Coppola, and Ari Natter

The Biden administration released long-awaited rules designed to block electric-vehicle manufacturers from sourcing battery materials from China and other foreign adversaries, while giving automakers some flexibility to comply with the new mandates.

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U.S. Limits China's Ability to Benefit From Electric Vehicle Subsidies

  • By Ana Swanson
  • By Jack Ewing
  • By Alan Rappeport

The Biden administration issued new rules to prevent Chinese firms from supplying parts for electric cars set to receive billions of dollars in tax credits.

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Too Soon to Make Pillar 2 a Blacklist Factor, EU Official Says

  • By Elodie Lamer

The chair of the EU Code of Conduct Group on business taxation said implementation of pillar 2 probably won’t become a determining factor for the list of noncooperative jurisdictions until after the peer review.

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Taiwan Tax Bill Advances in House With Bipartisan Support

  • By Cady Stanton

House taxwriters unanimously advanced a fix to the issue of double taxation with Taiwan, moving a unique bill combining approaches from two Senate committees.

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EU Panel to Widen Checks on Member Countries’ Tax Regimes

  • By Stephen Gardner

Tax measures put in place by EU countries will face closer scrutiny beginning next year for their possible harmful effects on other member countries’ economies, the chair of the bloc’s Code of Conduct Group (Business Taxation) told the European Parliament tax subcommittee.

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Pillar 2 Peer Review Guidance Expected Soon, Plowgian Says

  • By Stephanie Soong

More pillar 2 guidance is likely to be published by the end of 2023, including advice on the peer review process and on antiabuse rules related to a key safe harbor, a top Treasury official said.

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EU Won't Introduce Pillar 1 Directive, Commission Official Says

  • By Stephanie Soong

The European Commission has decided against proposing a directive to implement pillar 1 of the OECD’s two-pillar global tax reform plan because the pillar 1 multilateral convention would be enough, an EU official said.

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Barbados Minister Criticizes Use Of Tax Transparency Blacklists

  • By Danish Mehboob

A minister from Barbados discouraged countries from blacklisting others based on how far they’ve developed their tax transparency frameworks.

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EU Nearing Full Pillar Two Implementation, But Not Pillar One

  • By Stephen Gardner

European Union countries are largely on track to start applying Pillar Two of the global tax deal next year, but the finalization of Pillar One remains uncertain, an EU official said at a European Tax Adviser Federation seminar.

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Promising Tax Talks Face Hurdles as Taiwan Bills Go Their Own Way

  • By Doug Sword
  • By Cady Stanton

Tax talks that would combine a beefed-up child tax credit and reinstate full research and development expensing aren’t exactly sizzling, but they are picking up speed after a year in the doldrums.

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UK Minimum Tax Estimates Are Highly Uncertain, Economist Says

  • By Danish Mehboob

The UK’s projection of £12.7 billion ($15.9 billion) in revenue within the next six years from the global minimum tax is highly uncertain, a top budget economist told lawmakers in a government budget hearing Tuesday.

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More European Governments Propose Global Minimum Tax Bills

  • By Stephanie Soong

The Austrian, Norwegian, and Slovenian governments have proposed legislation implementing an EU directive for adopting global minimum tax rules under pillar 2 of the OECD’s two-pillar global tax reform plan.

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IP Transfers and Profit Shifting

  • By Martin A. Sullivan

Martin A. Sullivan explores financial data for more than 300 multinational companies to uncover trends in intellectual property transfers.

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U.K. Makes Full Expensing Business 'Tax Cut' Permanent

  • By Sarah Paez

The United Kingdom will make full expensing for business capital investments permanent as part of a plan to invest £20 billion annually in businesses over the next decade, said Chancellor of the Exchequer Jeremy Hunt.

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U.N. Tax Cooperation Resolution Passes in Committee Vote

  • By Sarah Paez

U.N. countries passed a resolution in committee to establish a framework convention for international tax cooperation, which would shift negotiations from the OECD to the U.N.

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EU to Assess Support for Withholding Tax Relief Framework Deal

  • By Elodie Lamer

While EU countries generally reacted positively to the Spanish EU Council presidency’s proposal exempting comprehensive withholding tax relief systems from some Faster and Safer Relief of Excess Withholding Taxes provisions, several requested time to study the impact.

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Colombia’s Introduction of Tax Arbitration a ‘Big Advance’

  • By Sam Edwards

Colombia will seek to allow arbitration in tax disputes for the first time in a major step forward, although questions remain about the proposal’s efficacy, tax professionals say.

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UK Sees About $16 Billion From Global Minimum Tax Over Six Years

  • By Danish Mehboob

The UK government estimates it will net about £12.7 billion ($15.9 billion) from the global minimum tax over the next six years, according to figures published in its Autumn budget statement.

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As Its Economy Sputters, Britain Cuts Taxes Ahead of Election

  • By Eshe Nelson

The U.K.’s top financial official, Jeremy Hunt, outlined measures to spur business investment and push more people into jobs.

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Barbados's Evolving Approach to Pillar 2

  • By Nana Ama Sarfo

Nana Ama Sarfo discusses Barbados's changing approach to pillar 2.

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Canada Reaffirms Its Plans for Unilateral DST

  • By Amanda Athanasiou

Despite opposition from business groups and the Biden administration, Canada has confirmed its intent to move ahead with its digital services tax just weeks before its planned effective date.

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UN Releases Draft Tax Resolution Calling for Framework Treaty

  • By Lauren Vella

A draft resolution released by the UN calls for the development of a framework convention to make international tax cooperation more inclusive.

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Corporate Income Tax Rates Decreased Globally Over Last 20 Years

  • By Lauren Vella

Income tax rates for companies have decreased on average over the past 23 years, according to a report on corporate tax statistics released by the OECD on Tuesday.

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EU to Consider Making Unshell Substance Test a Minimum Standard

  • By Elodie Lamer

A note prepared by the EU Council's Spanish presidency suggests pursuing the European Commission's idea to maintain the tax consequences of its proposal to tackle the misuse of shell entities.

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Report Reveals Hidden Costs of Canada's Battery Plant Subsidies

  • By Amanda Athanasiou

The cost of government support for electric vehicle battery manufacturing projects in Canada that includes U.S.-credit-matching subsidies to major automakers could exceed estimates by almost C $6 billion, a budget watchdog said.

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Switzerland Mulls Later Start Date for Global Minimum Tax

  • By Bastian Benrath

Switzerland may postpone raising the minimum tax rate on multinationals to 15%, amid widespread delays in implementing a global deal on the issue.

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U.S. Signs Indo-Pacific Tax Transparency Pact

  • By Alexander Rifaat

The United States has joined 13 other countries from the Indo-Pacific region in agreeing to, among other measures, strengthen cooperation to combat cross-border tax evasion.

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Bermuda Seeks Input on Draft Corporate Tax Legislation

  • By Stephanie Soong

The Bermudian government is holding a third consultation on its proposed corporate tax regime — this time on draft legislation intended to align with the global anti-base-erosion rules under pillar 2.

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Vote on U.N. Tax Cooperation Resolution Expected Soon

  • By Sarah Paez

U.N. members are expected to vote soon on a draft resolution that would lay the groundwork for a legally binding framework convention on international tax cooperation.

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African Nations Call on Rich Countries to Back UN Tax Reform

  • By James Munson

African countries at the United Nations called on richer nations to back their push to have the global body undertake negotiations toward reforming the world’s tax rules.

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Much Ado: Why the United States Should Calm Down About DSTs

  • By Reuven S. Avi-Yonah

Reuven S. Avi-Yonah examines why countries have embraced unilateral digital services taxes and, in light of pillar 1’s grim outlook, how the United States can learn to live with them.

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Chile Senate Votes to Ratify Tax Treaty with US, Advancing Pact

  • By Michael Rapoport

Chile’s Senate unanimously approved a tax treaty with the US, bringing the agreement one step closer to taking effect.

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US Corporate AMT: Inbound Investors Beware of Aggregation Rules

  • By Jennifer Lee, Zachary Kling, Jonathan Rhein, Zaira Cortes Rivero, and Peter A. Glicklich

Enacted as part of the Inflation Reduction Act of 2022, the US Corporate Alternative Minimum Tax is in effect for all tax years beginning after December 31, 2022, but the IRS and taxpayers alike continue to learn more about the contours and pitfalls of the CAMT.

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EU Mulls Expansion of Sectors Targeted by Carbon Border Tax

  • By Lauren Vella

The European Union is considering extending the purview of its carbon border tax to a limited number of other sectors, according to a European Commission official.

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House Lawmakers Call for Extension of Foreign Tax Credit Relief

  • By Chris Cioffi

Democrat and Republican House lawmakers are asking for an additional pause on newer, more stringent foreign tax credit rules, a move the IRS already hinted may be coming.

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Pillar 2 and Foreign Tax Credits

  • By Lee A. Sheppard

Lee A. Sheppard examines the impact of the pillar 2 income inclusion rule, qualified domestic minimum top-up tax, and undertaxed profits rule on the foreign tax credit for U.S. multinationals.

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OECD Status Check

  • By Mindy Herzfeld

Mindy Herzfeld examines the latest developments in the OECD’s international tax work, including the two-pillar project.

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OECD Cryptoasset Framework to Come Into Force in 2027

  • By Michael Smith

In order to address potential gaps in existing information exchange, 48 countries have formally signed on to the OECD’s cryptoasset reporting framework.

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German Parliament Passes Global Minimum Tax Legislation

  • By Stephanie Soong

Germany’s Parliament has approved a law transposing the EU’s global minimum tax directive into national law, in line with pillar 2 of the OECD’s two-pillar plan to modernize the international corporate tax system.

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Finland Consults on Signing Pillar 1 Multilateral Convention

  • By Stephanie Soong

The Finnish government is asking for input on whether it should sign a multilateral convention implementing a reallocation of taxing rights as part of pillar 1 of an OECD-brokered, two-pillar global tax overhaul.

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Nigeria Seeks to Lure Foreign Investment With Tax Incentives

  • By Ruth Olurounbi

Nigeria will boost incentives for foreign investors in an attempt to address a decline in capital coming into the country as part of the government’s plans to revive the economy.

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48 Countries Commit To Global Crypto Tax Reporting In 2027

  • By Danish Mehboob

Forty-eight countries said Friday they are moving ahead with implementing a global crypto-asset reporting framework by 2027.

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IRS Issues New Foreign Currency Regs

  • By Andrew Velarde

After years of delaying the applicability date of earlier regulations, the IRS has released long-awaited proposed regs on income and foreign currency gain or loss for qualified business units.

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Chile’s Lower House Approves US Tax Treaty, Sending It to Senate

  • By Sam Edwards

Chile’s lower house unanimously approved a tax treaty with the US on Wednesday, sending the bill to the Senate, where it could become law in the coming weeks, the Finance Ministry said.

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Finland Government Seeks Public’s Opinion on Global Tax Treaty

  • By Lauren Vella

Finland is requesting opinions from stakeholders on whether the country should sign onto a multilateral tax treaty that’s part of the OECD-led international tax pact.

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