Int'l Tax News

Multinational enterprises (MNEs) are facing new challenges arising from OECD's developments regarding the determination of a taxable presence in a foreign countrywhere the company operateswithout a legal entity.

As tax authorities around theworld start to examine how e-commence sales affect their revenue from indirect tax it is important for taxpayers to knowwhat measures are being enforced.

For the ITR story, go here.

The Advance Pricing Agreements or transfer pricing rulings granted to U.S. multinationals by Ireland, the Netherlands, and Luxembourgwere principally designed to achieve U.S. tax deferral and not EU tax avoidance. Adverse BEPS effectswithin the European Unionwould be immaterial in comparison to the deferral of U.S. tax on residual IP related profits, andwould have occurred primarily in countries other than those chargedwith the granting of unlawful State aid. The significant tax policy implications for both Europe and the United States resulting from the State aid decisions by the EU Commission are explored here in detail.

by PwC

The Gabonese Republic has enacted the Finance Act 2016,which amends certain provisions of the Gabonese Republic Tax Code.

This Insight discusses the main changes resulting from enactment of the Finance Act 2016 that could affect multinational companies doing business in Gabon.

For the PwC Insight, gohere.

The fight for fair taxation in the EU is high on Parliament's agenda following the revelations as a result of LuxLeaks and the Panama papers. At a timewhen EU countries are struggling to recover from the crisis, MEPs are pushing for greater transparency and an end to tax unfair practices. Read on for our overview of Parliament initiatives.

For the European Parliament release, go here.

EU and non-EU parliamentarians convened on May 2 at the OECD in Paris,where theywere briefed on the current state of play on base erosion and profit-shifting project implementation, andwere able to compare notes on their respective countries' experienceswith BEPS measures, attendees told Tax Analysts.

If you are looking for an example of how corporate interests continue to dominate the agenda in Congress, a recent hearing on business tax reform held by the Senate Finance Committee is Exhibit A.

For the Tax Justice Blog post, gohere.

Thomson Reuters Checkpoint has just released a special report addressing the European Commission's Anti-Tax Avoidance Package (ATA) and other global Country-by-Country Reporting (CbCR) developments designed in conformitywith the OECD BEPS Action 13 recommendations. The report,

BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting,will help multinational enterprises (MNEs) gauge their readiness to collect and aggregate the data required under CbCR andwill equip themwith the latest CbCR information to navigate this complex, quickly evolving landscape.

For the report, go here.

While the Obama administration touts its recent rules to limit corporate inversions as a step forward towards fixing our broken tax code, it is clear this administration fundamentally misunderstands the problems that are driving American companies abroad. In the long run, punitive Treasury Department regulationswill only make America less competitivewhile this administration ignores the core problem: a hopelessly outdated corporate tax code.

For theweekly Standard article, go here.

As tax authorities around theworld start to examine how e-commence sales affect their revenue from indirect tax it is important for taxpayers to knowwhat measures are being enforced.

For the ITR story, go here.

by Ryan Finley

Treasury and the IRS areworking toward a solution to the "gap year" problem by allowing optional country-by-country reporting for 2016, but U.S. multinationals can help their own cause by engaging more in the global debate over corporate tax avoidance, according to Robert Stack, Treasury deputy assistant secretary (international tax affairs).

A forthcoming corporate integration plan is showing signs that its current designwill raise revenue, but Senate Finance Committee Chair Orrin G. Hatch, R-Utah, said April 21 that hewants the final outcome to be revenue neutral.

For the TNT story, go here. (subcription required)

Tax reform proposalswon't fix our broken corporate tax system. Most proposals suggestwe lower the rates and broaden the base by removing tax expenditures and the interest deduction. Those proposals have merit and seem attractive, but they fail to fix the unfairness of domestic companies paying more tax than multinational enterprises in identical circumstances. This article examines two reform options outlined by Edward D. Kleinbard.

For the Tax Notes viewpoint, go here. (subscription required)

In this article, Daniel Falk demonstrates that the requirements of the comparable uncontrolled transaction method regulations are virtually impossible to meetwhen strictly applied, and he discusses potential solutions to the problem.

For the Tax Notes viewpoint, go here. (subscription required)

Houseways and Means Tax Policy Subcommittee Chair Charlesw. Boustany Jr., R-La., said April 19 that hewill be meeting thisweekwith Republican committee members in order to seek clarity over how to proceedwith international tax reform.

For the TNT story, go here. (subscription required