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OECD Treaty Under Global Tax Deal Faces Several Hurdles
A variety of knotty issues remain over a multilateral treaty aimed at implementing a key part of the OECD’s global tax agreement—including disagreements among countries over withholding taxes and digital services taxes, and getting the US to sign on.
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Countries Advance Global Tax Reforms With Amount A Treaty Text
The OECD has published the text of a treaty providing for the reallocation of taxing rights to market jurisdictions and a digital tax repeal, but some details need resolution before countries can start signing it.
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Canada’s Digital Services Tax Sets the Stage for a US Trade War
Among the many perplexing questions raised by the OECD’s two-pillar project on global tax policy, one mystery is why the government of Canada has broken ranks with other major players in the Inclusive Framework on Base Erosion and Profit Shifting—by announcing its intention to proceed unilaterally with a digital services tax.
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It's Time to Act Against Canada's DST, U.S. Lawmakers Insist
U.S. Trade Representative Katherine Tai is facing increasing pressure from lawmakers to take decisive action against the impending enactment of Canada’s digital services tax as Senate Finance Committee members urge new warnings.
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Ireland to Raise R&D Credit Rate Amid Global Minimum Tax Rollout
Ireland’s latest budget proposes to increase the research and development credit for companies from 25% to 30% to maintain the value of investment amid a global rollout of a minimum tax framework.
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Wyden Calls on Tai to Tell Canada the US Will Fight Digital Tax
Senate Finance Committee Chair Ron Wyden and Republican Mike Crapo ask US Trade Representative Katherine Tai to tell Canada that America will forcefully defend US companies against its digital services tax.
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This Country Won the Global Tax Game, and Is Swimming in Money
On October 10, Ireland created a sovereign-wealth fund thanks to outsize profits from U.S. technology and pharmaceutical giants seeking to lower their tax bills. Ireland’s government said a new Future Ireland Fund could amass €100 billion by the middle of the next decade.
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Does Pillar 2 Provide a Windfall to Tax Havens?
Martin A. Sullivan shows how pillar 2 could result in a windfall for tax havens.
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Bermuda Mulls 15 Percent Corporate Tax Rate Aligned With Pillar 2
Bermuda is holding another consultation on its response to global minimum tax implementation, this time proposing a 15 percent corporate tax rate and qualified refundable tax credits to take effect in 2025.
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Trade Group Presses OECD for Better Pillar 2 Safe Harbors
A trade group is urging the OECD to improve its pillar 2 administrative guidance — including amending and adding safe harbors — to give affected businesses more certainty about how the global minimum tax rules will work.
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Pillar 1 Amount B: Simplifying the Arm's-Length Principle for Baseline Distribution Activities
In this article, Eden critiques the latest public consultation document for pillar 1 amount B and proposes options for increasing the likelihood of its adoption and success.
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Treasury Issues Rules on ‘Killer B’ Triangular Reorganizations
The Treasury Department and the IRS proposed regulations aimed at reining in “Killer B” triangular reorganizations involving foreign corporations, which the government says companies have used in the past to avoid taxes.
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Irish Corporate Tax Receipts Drop, Portending Growth Slowdown
Irish corporate tax receipts have dropped two months in a row, with third-quarter revenues falling €700 million short of projections as researchers predict a slowing corporate tax take in line with modest economic growth.
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Countries Agree on Tool to Implement Global Tax Pact Rules
The OECD announced Tuesday that countries involved in the global tax deal negotiations have agreed on a multilateral convention to implement a rule aimed at helping developing countries collect more tax under treaties that set low withholding rates.
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Germany, China Pledge to Help Administer Global Minimum Tax Rules
Germany and China have pledged to help developing nations administer the global minimum tax rules just months before they’re poised to go into effect.
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Dutch Authorities Staffing Up for Global Tax Push, Minister Says
A top Dutch tax official said the Netherlands is preparing for the global minimum tax rollout and will support developing countries in international tax policymaking at the United Nations following talks with US tax officials.
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Position of the European Union and its Member States for the 79th session of the UN General Assembly
The EU said the negotiations “do not reflect our key points of concern,” and priorities like “consensus-based decision-making” and the inclusion of “taxpayers’ rights and safeguards” were not being addressed, according to this statement dated September 27 and made public on Oct 10.
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Singapore Plans Safe Harbor for Its Global Minimum Tax Legislation
Singapore aims to roll out a safe harbor as part of its adoption of the global minimum tax rules, according to a top government official.
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Singapore Aiming for Pillar 2 Domestic Top-Up Tax Safe Harbor
Singapore will strive to implement a qualified domestic minimum top-up tax safe harbor to make tax compliance as easy as possible for companies affected by pillar 2 rules, according to a top government finance official.
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Limits in US-Taiwan Tax Relief Bill Differ From a Typical Treaty
The United States-Taiwan Expedited Double-Tax Relief Act, which is advancing to the full Senate, would provide an array of tax benefits on certain income earned by qualified residents of Taiwan from US investments or activities.
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Global Rulemaker Changes SME Accounting to Avoid OECD Issues
The International Accounting Standards Board changed small company accounting rules Friday in order to simplify issues created by OECD global minimum tax rules.
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U.K. Updates Draft Pillar 2 Amendments With Safe Harbors
The United Kingdom has published more draft measures revising its pillar 2 legislation to reflect safe harbors and other features of the OECD’s latest administrative guidance for the global anti-base-erosion rules.
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French Finance Bill 2024 Moves to Adopt Global Minimum Tax Rules
The French government is moving to adopt the EU’s pillar 2 directive, implementing global anti-base-erosion rules and a domestic minimum top-up tax, according to its 2024 draft finance bill.
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Hungary Makes Moves Toward Global Minimum Tax Adoption
Hungary’s finance minister has started talks with large Hungarian companies about ensuring the country remains competitive as it prepares draft legislation in the fall for transposing the EU’s global minimum tax directive into domestic law.
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Italy Offers Banks Get-Out Clause on Divisive Windfall Tax
The Italian government modified a controversial windfall tax on banks, giving lenders an option to avoid paying if they set aside additional capital reserves.
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Deputy U.S. Trade Rep Presses Canada on Digital Tax Plan
The Office of the U.S. Trade Representative has again pushed back against Canada’s plans to introduce a digital services tax, days after American lawmakers warned that the tax, if imposed, might damage Canada-U.S. trade relations.
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Global Carbon Pricing Challenge Gains New Members at U.N. Summit
Government officials from Norway and Denmark announced that their countries are joining the Canadian-led global carbon pricing challenge and emphasized the importance of international cooperation on carbon taxes to effectively reduce emissions.
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U.S. Issues Final Rules to Keep Chip Funds Out of China
The Biden administration on September 22 issued final rules that would prohibit chip companies vying for a new infusion of federal cash from carrying out certain business expansions, partnerships and research in China, in what it described as an effort to protect United States national security.
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Plowgian to U.N.: Don't Torpedo Global Tax Deal
A senior Treasury official has cautioned against efforts by the U.N. to pursue a separate multinational tax agreement, arguing that it would fundamentally undermine the progress made by the OECD’s inclusive framework.
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IRS Considers Extension on Rollback of Foreign Tax Credit Rules
The IRS is considering extending the period in which taxpayers can rely on old foreign tax credit rules, while the agency mulls changes to newer rules.
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World Leaders Call on UN to Start Developing Global Tax Norms
Several world leaders at a United Nations high-level panel said that the OECD is not the preferred organization to lead the international tax cooperation agenda, but existing work should not be duplicated.
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Gentiloni Warns Against the Search for Pillar 2 Loopholes
EU Tax Commissioner Paolo Gentiloni told members of the European Parliament that the EU will have to work hard to avoid a situation in which private actors or jurisdictions find loopholes in pillar 2 of the OECD's global tax plan.
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W&M Republicans Push for Pillar 2 Slowdown While Promoting GILTI
House Republican taxwriters are hoping other countries will delay implementation of pillar 2 of the OECD global tax deal while they separately encourage leaders to implement versions of the United States’ global intangible low-taxed income regime.
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House Lawmakers Seek Pressure Against Canada’s Digital Tax Plans
A bipartisan group of House Ways and Means Committee members called on the Treasury, the US Trade Representative, and the Organization for Economic Cooperation and Development to push back on Canada’s decision to impose a digital services tax.
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Dutch Budget Offers Fix for Global Minimum Tax Shortfalls
The Dutch tax plan presented to Parliament on Tuesday highlighted ways to make up for uncertain tax revenues from the global minimum tax to start in 2024.
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Slow EU Pillar 2 Adoption Is a Challenge, Says EU Official
Although some EU member states have started transposing the EU’s global minimum tax directive into their domestic law, others aren’t acting as quickly, and time is running out, according to a European Commission official.
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The Biggest Casualty of Pillar 2's Bias for State Subsidies? The U.S.
Stephen A. Bonovich considers the inexplicable and unexplained decision to design pillar 2 to attack various forms of tax rate competition but ignore state subsidies, even though tax academicians, officials, and practitioners have long concluded that such a design is highly irrational and gives rise to market distortions — the exact opposite of what pillar 2 seeks to achieve. He also looks at the practical implications of ignoring those views for the United States, the EU, and China.
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Global Minimum Levy Won’t Stop EU Tax Competition, Report Says
Introduction of the 15% global minimum tax will lead jurisdictions to seek new ways of offering tax breaks to attract companies, according to a report on launch of the tax in the European Union.
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Multinationals Report Large Tax Benefits From Transfers of IP to Switzerland
Martin A. Sullivan uses data from Form 10-K reports to illustrate some policy shortcomings of recent tax reform efforts, focusing on intellectual property transfers and Switzerland’s status as a tax haven.
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Ireland Opens Consultation on Tax Breaks for Dividend Income
Ireland is considering a plan to offer corporate tax breaks for dividend income and foreign branches.
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Caribbean Policy Cries for Change Following the Global Minimum Tax
Bruce Zagaris breaks down the effect changes in global tax trends have had on Caribbean nations and examines measures to encourage growth in the region.
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Senate Committee Backs Bill to Deepen U.S. Economic Ties With Taiwan
The Senate Finance Committee on September 14 passed a bill that would deepen economic ties between the United States and Taiwan and effectively create a tax treaty that is expected to pave the way for more Taiwanese investment in the American semiconductor industry.
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It's Time for the United States to Move On From the DST Feud
Ryan Finley asserts that the apparent failure of the United States’ global crusade against digital services taxes should prompt a reassessment of U.S. policy.
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Some Open Questions on the U.N. Tax Cooperation Effort
Nana Ama Sarfo outlines some open questions generated by the U.N. secretary-general's recent report on international tax cooperation.
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US Backs Simpler Transfer Pricing Reform in Global Tax Deal
The US reiterated its preference Tuesday for what it says is an easier method for determining which transactions will be affected by new streamlined global transfer pricing rules.
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G-20 Leaders Call for Finalizing Pillar 1 Tax Treaty, Amount B
Countries should work quickly on pillar 1 of the OECD’s two-pillar tax reform plan, including unblocking progress on the amount A multilateral convention and completing amount B transfer pricing simplification rules, G-20 leaders said.
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U.S. Trade Group Pans Canada's DST for Undermining OECD Process
Canada's digital services tax legislation could weaken the two-pillar plan to modernize corporate tax rules from the OECD/G-20 inclusive framework on base erosion and profit shifting, according to a U.S. trade group.
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G20 Leaders Call for Transfer Pricing, Crypto Fixes in Tax Deal
The Group of 20 leaders are calling for a resolution on remaining issues in the global tax deal, including tackling transfer pricing and crypto issues.
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Tech Groups Urge Canada to Drop DST and Refocus on OECD Tax Deal
The Canadian government should withdraw its plans for a digital services tax to avoid creating “perverse incentives” for countries to undermine a major OECD global tax reform agreement, tech companies said.
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European Commission Draws Lessons From Past Failures With BEFIT
The European Commission says it used “valuable insights gained from many years of negotiations” on corporate tax proposals — including those that failed — to design its much-awaited proposal for a common corporate tax framework.