Int'l Tax News

Sol Picciotto explores the origins of the global anti-base-erosion tax, the main element of pillar 2, its current implementation, and the role the United States could play in supporting or opposing these international tax reforms.

In a tax report delivered to the G20 Friday, the Organization for Economic Cooperation and Development said that the 15% global minimum tax is expected to rake in $200 billion annually, and that by 2025 more than 90% of multinational corporations making over 750 million euros ($803 million) will be subject to it.

Nine House Republicans pressed the German Minister of Finance to repeal Germany’s century old tax on intellectual property income that’s recently troubled US companies.

African countries are partnering with three donors to develop a digital tax system for the continent’s governments to own following years of costly, piecemeal updates to their tax administration tools.

The new corporate minimum tax has become a challenge for the Biden administration, which has faced intense lobbying from industries that could be on the hook for billions of dollars in new taxes. Those groups have been flooding the Treasury Department with letters asking for lenient interpretations of the law and trying to create new loopholes before their tax bills come due next year.

A proposed EU common corporate tax system would apply to the same large multinational and domestic groups in scope of pillar 2 and harmonize transfer pricing rules across the bloc.

The Irish government has increased the effective tax rate of its knowledge development box, responding to the treaty-based subject-to-tax rule under pillar 2 of the OECD-brokered tax reform plan.

Tax practitioners are getting increasingly anxious about a major foreign income tax case before the Supreme Court that they fear could tear down wide swaths of the tax code, as a deadline approaches for parties to weigh in. 

Congressional tax-writers start their trek back to Washington this week with plans to consider a Taiwan tax bill, scrutinize the global tax deal, and hash out funding for the IRS.

Ryan Finley explains why pillar 2 adoption should prompt a reassessment of patent boxes and other income-based tax incentives for intellectual property.

Martin A. Sullivan considers whether the foreign-derived intangible income provisions of the Tax Cuts and Jobs Act did, in fact, raise revenue for the U.S. fisc.

The OECD/G-20 inclusive framework on base erosion and profit shifting should expand the scope of amount B of pillar 1 to include digital services, according to the Information Technology Industry Council.

Observers have long warned that an expansive Supreme Court decision in Moore v. United States could have catastrophic repercussions for the tax code. Now, the Tax Foundation has put a price tag on it.

Italy’s new law enabling the government to implement sweeping tax system reforms has taken effect, paving the way for the transposition of the EU’s global minimum tax directive.

Companies will have to disclose more details about the income taxes they pay to government authorities under new requirements approved by the Financial Accounting Standards Board, a move to provide investors with greater transparency.

Germany’s ruling coalition has agreed to cut corporate taxes by approximately €7 billion a year to stimulate the economy and promote long-term investment during a slowdown in business activity.

The New Zealand government will soon propose legislation for a digital services tax, citing slow progress on an OECD global tax reform agreement aimed at addressing the tax challenges of the digital economy.

A prominent interest group representing scores of large multinational companies is asking the IRS to go further with its temporary relief from foreign tax credit rules that businesses have sharply criticized.

A recent discussion among Association of Southeast Asian Nations members about OECD-brokered global minimum tax rules and their implications for investment incentives will help countries in the region prepare accordingly, finance ministers said.

A draft European Parliament report states that taxation has a role to play in the insolvency framework, reflecting the growing presence of tax issues in nontax proposals at the EU level.

Mindy Herzfeld takes another world tour to reexamine the latest developments in OECD pillar 2 implementation.

Businesses digging into the details of the OECD’s public consultation document on simplifying the arm’s-length principle are pointing out critical gaps and open issues in amount B‘s design and asking questions about data transparency.

The OECD pushed back Thursday against criticism by tax advocacy groups that the 15% global minimum tax rules are too hard to administer and could be detrimental to developing countries.

The federal government is escalating efforts to make cryptocurrency investors comply with tax law, nearly 15 years after people started trading bitcoin. The Treasury Department proposed new rules Friday to make it harder for crypto investors to dodge income taxes when they sell digital assets and to simplify complicated tax messes for people who are trying to follow the law.

Switzerland expects to net CHF 1.6 billion (about $1.8 billion) from the first year of operation of its pillar 2 legislation, according to the 2024 budget.

Portugal has published a decree law transposing EU Directive 2021/2101, which requires member states to make country-by-country reporting mandatory for large multinational entities.

Two intergovernmental groups are advising developing countries to undertake a careful cost-benefit analysis of the OECD-led global tax deal.

Analyzing the OECD’s Pillar Two proposal that all countries impose a 15% minimum tax on corporate income is like playing a multidimensional chess game. Each element of the proposal, and each country that adopts it, creates waves that affect all other players, both governments and corporate taxpayers.

A new 1% tax on stock buybacks is starting to increase companies’ anticipated tax burdens, to the tune of over $3.5 billion in the first half of the year among the largest U.S. public companies.

Members of the Association of Southeast Asian Nations must review global minimum tax rules because they will only benefit developed countries and will adversely affect incentives offered by developing countries, investment ministers said.

The US Treasury Department recently won hard-fought victories in the global minimum tax multilateral negotiations, which US lawmakers and stakeholders should applaud. Instead, some of them are now attempting to use that win against Treasury negotiators.

The US accounting standard setter said it would press on with a project that would force companies to detail the amount of income tax paid to state, federal, and foreign tax authorities. Companies would also be required to disclose the states, countries, and amounts paid if payments equal 5% or more of total tax payments.

Martin A. Sullivan argues that the IRS’s detailed data on five years of country-by-country reports don’t help provide a clear picture of multinationals’ profit shifting.

Nana Ama Sarfo looks at the evolution of China’s Belt and Road Initiative Tax Administration Cooperation Mechanism and questions whether it can meet its broad goals.

Domestic minimum top-up taxes in line with the OECD’s pillar 2 plan won’t protect developing countries’ tax bases, but other options, like alternative minimum taxes, will, according to a South Centre policy brief.

The 15% global minimum tax rules included as part of the OECD-led international tax deal favor developed nations, are burdensome to administer and do not guarantee the collection of more revenue, an advocacy group for developing nations said.

Germany has finalized its proposed bill for transposing into domestic law the EU’s directive implementing global minimum tax rules under pillar 2 of an OECD-brokered international corporate tax reform revamp.

The European Commission has adopted rules governing reporting requirements during the phase-in of the carbon border adjustment mechanism. Several non-EU countries expressed concerns during the consultation on those rules.

The Czech Republic has approved draft legislation to transpose into its domestic law an EU directive implementing a global minimum top-up taxation framework under the OECD’s two-pillar corporate tax system overhaul.

Vietnam’s finance ministry estimates the implementation of the global minimum tax may add about $629m to state revenue by 2024, news website Nhip Song reports, citing information from the Ministry of Finance.

For the moment, the government’s big rollback of foreign tax credit rules is a clear win for multinational drug makers, manufacturers, and companies doing business in Brazil. What happens next isn’t so clear.

A government plan to let companies cut their taxes by financing clean-energy projects kicked off with a deal to help fund a $1.5 billion wind-energy transaction that officials hope will spur tens of billions of dollars in climate financing.

The Finnish government is seeking feedback on proposed legislation that would transpose into domestic law the EU’s directive for implementing global anti-base-erosion rules under pillar 2 of the OECD’s two-pillar global tax reform plan.

Italy's deputy prime minister, Antonio Tajani, said the government's bank windfall tax should not apply to smaller lenders and that it should be tax-deductible. The tax was announced last week and sent shockwaves through financial markets.

Australia is moving forward with its plan to implement a carbon border tax in order to reach net zero emissions by 2050.

Technical concerns about a global tax treaty detailing how multinational companies’ residual profits will be reallocated are expected to be resolved by the fall, a top OECD official said Tuesday.

The OECD has a “proven record of enabling significant change,” Manal Corwin, the organization’s top tax official said in response to a United Nations draft report that argued it doesn’t adequately address the needs of developing countries.

The UK Law Commission released its final report on digital assets on June 28, commissioned by the government in March 2020 and followed by an extensive consultation with industry, legal firms, and others.

Mindy Herzfeld explains the current rift between the United States and the OECD and outlines potential steps to close the gap and encourage a better working relationship.

Nana Ama Sarfo takes a look at the OECD’s latest report on developing countries and the inclusive framework.