Skip to main content

Int'l Tax News

Posted on

Countries Raise Corporate Tax Rates After Years of Decline

  • By OECD Publishing

Corporate income tax rates across the world stabilized in 2023 after years of decline, according to a new report from the OECD summarizing international taxation trends.

To read more go here Subscription Required

Posted on

French Government Weighs New Taxes on Large Firms, Le Monde Says

  • By Ania Nussbaum

The French government is weighing fresh taxes on corporates to cut the country’s budget deficit, newspaper Le Monde reported.

To read more go here Subscription Required

Posted on

Estimating Pillar 2’s Effect on U.S. Multinationals and Treasury Revenue

  • By Thomas Horst

Thomas Horst explains and illustrates his evaluation of the effect of the OECD/G20’s pillar 2 minimum tax rules on U.S. multinational enterprises and on U.S. federal tax revenue.

To read more go here Subscription Required

Posted on

Ireland Expects €25BN Budget Surplus This Year After Apple Windfall

  • By Jude Webber

Ireland’s government expects to post a budget surplus of €25bn this year, boosted by part of the €14.1bn in back taxes from Apple that the EU’s top court this month ordered it to accept.

To read more go here Subscription Required

Posted on

Trump’s Low-Tax, High-Tariff Strategy Could Clash With Economic Realities

  • By Alan Rappeport

The former president’s efforts to compel companies to remain in the United States had limited success while he was in the White House.

To read more go here Subscription Required

Posted on

The Meaning of State Aid Is Anyone’s Guess After Apple

  • By Ryan Finley

Ryan Finley explains why the Court of Justice was wrong to assume that its understanding of OECD transfer pricing and profit attribution guidance is the only reasonable interpretation.

To read more go here Subscription Required

Posted on

Treasury Downplays FTC Timing Concerns in Corporate AMT Regs

  • By Andrew Velarde

Treasury is not overly concerned with practitioner worries stemming from a lack of carryforwards for direct foreign tax credits and book-to-tax income recognition timing differences under its corporate alternative minimum tax proposed regs.

To read more go here Subscription Required

Posted on

Harris Pledges $100 Billion in Tax Credits to Boost U.S. Manufacturing

  • By Ken Thomas, Tarini Parti, and Andrew Restuccia

The Democratic presidential nominee outlined her economic plans, including tax credits to boost next-generation industries, during a speech in Pittsburgh.

To read more go here Subscription Required

Posted on

German Transfer Pricing Updates Align Arm's-Length Rules, OECD

  • By Philipp Redeker and Viktoria von Abel

Germany’s Growth Opportunities Act, applicable as of Jan. 1, highlighted a disparity between the German legislature’s application of the arm’s-length principle for intra-group financing versus OECD transfer pricing guidelines for multinational companies and tax administrations. This has created substantial uncertainty for multinationals, leaving many unresolved questions about application of the new tax legislation.

To read more go here Subscription Required

Posted on

Nigeria Urges UN Action on Tax Treaty Talks

  • By James Munson

Nigeria urged the United Nations on Tuesday to begin negotiations toward a global tax treaty opposed by wealthier countries because its work would overlap with that of the OECD.

To read more go here Subscription Required

Posted on

Treasury Working on Guidance for OECD Transfer Pricing Rules

  • By Lauren Vella

The US Treasury Department is working on guidance to apply a set of OECD rules that seek to simplify the way businesses value certain intercompany transactions, a department official said Tuesday. The implementation of the rules, known as Amount B, is on the list of Treasury’s priority guidance projects, said Brenda Zent, special adviser on international taxation at Treasury.

To read more go here Subscription Required

Posted on

Trump Says Plan Will Convince Foreign Companies to Shift Jobs to U.S.

  • By Richard Rubin and Chao Deng

The Republican presidential nominee uses tax breaks and tariff threats in a bid to persuade foreign companies to shift production.

To read more go here Subscription Required

Posted on

Trump Pitches ‘New American Industrialism’ and Luring Foreign Manufacturing

  • By Michael Gold

The former president highlighted his plans to increase tariffs and reduce corporate taxes for businesses that make products in the United States.

To read more go here Subscription Required

Posted on

The Apple State Aid Decision: Is This Really About Pillar 2?

  • By Robert Goulder

Robert Goulder comments on the final decision of the EU’s Court of Justice on the state-aid claim against Ireland.

To read more go here Subscription Required

Posted on

Netherlands, Finland Move to Amend Global Minimum Tax Rules

  • By Sam Edwards

The Netherlands and Finland both published draft legislation to update their respective global minimum tax laws to include recent guidance from the OECD.

To read more go here Subscription Required

Posted on

Swiss Consider Using OECD's Simplified Transfer Pricing Plan

  • By Caleb Harshberger

Switzerland is mulling OECD rules aimed at simplifying transfer pricing methods for certain transactions, also known as Amount B, under the global tax deal. Swiss Competent Authority member Ronny Rosenblatt said that Switzerland may use Amount B as a safe harbor and commit to accept it when dealing with covered countries that are using it.

To read more go here Subscription Required

Posted on

Global Tax Changes Create Challenges and Opportunities for Africa

  • By Theophilus Emuwa

Tax reforms driven by OECD and UN initiatives are reshaping the international tax landscape and require African economies, governments, and businesses to adapt to an evolving global tax environment.

To read more go here Subscription Required

Posted on

EU Extortion in Apple

  • By Lee A. Sheppard

Lee A. Sheppard examines the recent decision by the EU’s Court of Justice in the Apple transfer pricing case, arguing that it contradicts the Court’s own precedent and OECD guidance.

To read more go here Subscription Required

Posted on

Treasury’s Latest Effort to Prop Up Pillar 2

  • By Mindy Herzfeld

Mindy Herzfeld examines recently proposed dual consolidated loss regs and questions whether the regs are justified by the legislative history, or whether Treasury has exceeded its authority under Loper Bright Enterprises Inc. v. Raimondo.

To read more go here Subscription Required

Posted on

Economic Substance: Canadian GAAR and U.S. Administrative Guidance

  • By Rémi D. Gagnon

Rémi D. Gagnon assesses the U.S. experience with the concept of economic substance and draws lessons for the successful development of this concept in Canada in light of the structural differences between the two systems.

To read more go here Subscription Required

Posted on

Countries Start Signing OECD Subject-to-Tax Rule Treaty

  • By Stephanie Soong

Nine jurisdictions have signed a multilateral instrument to implement the OECD subject-to-tax rule, with 10 others to follow, advancing efforts to help developing countries ensure that some cross-border payments are taxed at a minimum rate.

To read more go here Subscription Required

Posted on

Win-Win Tax Partnerships Mean Investment and Growth for Africa

  • By Daniel A. Witt

The International Fiscal Association Congress will this year be held in Africa. The timing is fortuitous, as African countries are making significant advances in both modernizing tax administration and pursuing economic growth.

To read more go here Subscription Required

Posted on

Apple Tax Verdict Lets Ireland Move Ahead on Foreign Investment

  • By Peter Vale

While the adverse ruling is embarrassing, it’s only temporary. Ireland has a lot of credit in the bank following its moves to abolish the double Irish corporate tax avoidance structure and its embracing of both EU and global efforts to bring in a new set of global tax rules, which should maintain the country’s attractiveness to international investors.

To read more go here Subscription Required

Posted on

Italy’s Investment Management Exemption Avoids Foreign PE Risk

  • By Vittoria Segre, Sebastian Boyxen, Yvonne Hohler, Howard Mayers, and Saverio Brocchi

Italy’s Investment Management Exemption regime will help foreign investment vehicles avoid PE risk and attract non-resident investors to Italy, say CMS practitioners.

To read more go here Subscription Required

Posted on

IRS to Establish New CAP Team to Resolve Transfer Pricing Issues

  • By Kiarra M. Strocko

The IRS is in the process of establishing a compliance assurance process team to streamline and expedite the resolution of transfer pricing issues in the CAP environment, an official has said.

To read more go here Subscription Required

Posted on

Republican Lawmakers Back Challenge to Undertaxed Profits Rule

  • By Stephanie Soong

House Republicans have expressed support for a recent legal challenge filed at the Belgian Constitutional Court against the undertaxed profits rule, saying the global minimum tax measure would give up U.S. sovereignty.

To read more go here Subscription Required

Posted on

The U.N. Framework Tax Convention: Can It Bridge the North-South Divide?

  • By Assaf Harpaz

Assaf Harpaz explains the key issues being addressed in the U.N. framework convention on international tax cooperation, including the global north-south divide and its role in the multilateral process.

To read more go here Subscription Required

Posted on

House GOP Vows to Oppose Global Tax, Profits Rules at OECD

  • By Chris Cioffi

House Republicans are voicing support for a US business group’s legal challenge of an EU directive requiring all bloc member states to apply global minimum tax rules and vowing retaliatory action if countries employ the levy on US companies.

To read more go here Subscription Required

Posted on

OECD Says Up to 80 Countries Will Soon Adopt Global Minimum Tax

  • By Shefali Anand

The Organization for Economic Cooperation and Development forecasts “somewhere between 60 to 80 jurisdictions” to adopt the rules in the coming years, said John Peterson, head of division for cross-border and international tax at the organization.

To read more go here Subscription Required 

Posted on

Tax Threat and Negativity Undermine Investment Efforts, UK Business Leaders Warn

  • By Michael O’Dwyer, Jim Pickard and Lucy Fisher

Business leaders have warned that the UK government’s tax-raising plans and negativity about its economic inheritance risk undermining its efforts to boost private sector investment.

To read more go here Subscription Required

Posted on

Taxation Diluted in von der Leyen's New European Commission

  • By Elodie Lamer

European Commission President Ursula von der Leyen has confounded the tax world with the announcement that EU tax policy will fall under the purview of the next climate commissioner.

To read more go here Subscription Required

Posted on

Estonia To Impose a 2% Tax on Accounting Profits to Cover Higher Defense Spending

  • By Jan Stojaspal

The Estonian government agreed in principle Tuesday to impose a 2% tax on accounting profits of companies and raise value-added tax to 24% in a bid to bolster the country’s security and defense, according to a press release from the country’s ministry of finance.

To read more go here Subscription Required 

Posted on

Biggest US Firms Largely Unscathed by Global Minimum Tax

  • By Lauren Vella, Caleb Harshberger, and James Munson

The new 15% global minimum tax that became effective in almost 40 countries is barely having an impact on many of the 100 largest US companies so far, but it has prompted low-tax jurisdictions to raise their corporate tax rates.

To read more go here Subscription Required

Posted on

NGOs and Companies Brace for Fight Over EU's Decluttering Agenda

  • By Elodie Lamer

After listening to a barrage of diverging arguments about ways to declutter the EU tax system, the European Commission told stakeholders it hopes to present its conclusions in the second half of 2025.

To read more go here Subscription Required

Posted on

Proposed DPL Rules May Have IRS Authority Hiccups

  • By Michael Smith

Practitioners are concerned that the IRS and Treasury may have overstepped their grant of rulemaking authority when addressing deduction/no-inclusion transactions without explicit congressional permission.

To read more go here Subscription Required

Posted on

Countries Making Tax Transparency, Dispute Resolution Progress

  • By Stephanie Soong

Governments are continuing to make strides in implementing the base erosion and profit-shifting project through country-by-country reporting under action 13 and mutual agreement procedures under action 14, the OECD said.

To read more go here Subscription Required

Posted on

FISC Chair Calls for Tax Framework Using Formulary Apportionment

  • By Elodie Lamer

Pasquale Tridico, president of the European Parliament’s subcommittee on tax affairs, has called on policymakers to include a formula to share profits in the common consolidated corporate tax rulebook proposed by the European Commission.

To read more go here Subscription Required

Posted on

EU Countries to Review Options for New Transfer Pricing Forum

  • By Elodie Lamer

EU member states soon will discuss three options for establishing a new joint transfer pricing forum, and the choice they make will determine who is in the driver’s seat.

To read more go here Subscription Required

Posted on

OECD Publishes Template for ICAP Outcome Letter

  • By Stephanie Soong

The OECD has released a standardized template that tax administrations will use when issuing outcome letters to multinational enterprises after completing an international compliance assurance program tax risk assessment.

To read more go here Subscription Required

Posted on

Biden’s 15% Minimum Tax on Big Companies Gets 603-Page Rulebook

  • By Richard Rubin and Jennifer Williams

The Treasury Department has issued long-awaited proposed regulations on the corporate alternative minimum tax. The proposed rules released run through a long list of special situations that require special attention, including treatment of foreign subsidiaries.

To read more go here Subscription Required

Posted on

OECD Targets Country Benefits That May Weaken Pillar 2 Rules

  • By Stephanie Soong

The OECD is working with country delegates on guidance addressing incentives that governments are offering to taxpayers that potentially undermine the integrity of the pillar 2 global minimum tax rules, an OECD adviser said.

To read more go here Subscription Required

Posted on

CJEU Reinstates €13 Billion State Aid Decision Against Apple

  • By Alexander F. Peter

The ramifications of the Court of Justice’s landmark decision upholding the European Commission’s determination that Apple received €13 billion of unlawful state aid will reverberate for years to come.
To read more go here Subscription Required

Posted on

Singapore Bill Would Provide Tax Credits to Offset Minimum Tax

  • By Natasha Teja

Companies in Singapore would receive generous tax credits to offset some of the impact of the global minimum tax under legislation being considered by lawmakers.

To read more go here Subscription Required

Posted on

Reconsidering Maquiladoras in Light of Recent Reforms

  • By Eduardo Méndez, Cameron Taheri, and Thomas D. Bettge

Eduardo Méndez, Cameron Taheri, and Thomas D. Bettge explain recent Mexican tax reforms and why businesses may need to reconsider the structure of Mexican manufacturing operations.

To read more go here Subscription Required

Posted on

Draghi Recommends Tax Incentives to Foster EU Competitiveness

  • By Sophie Petitjean

Former European Central Bank President Mario Draghi said in his long-awaited report on the future of EU competitiveness that the EU should use taxation as a carrot rather than a stick.

To read more go here Subscription Required

Posted on

EU Court Rules That Apple Must Pay €13bn in Back Taxes

  • By Javier Espinoza, Jude Webber, and Emma Agyemang

Apple has suffered a significant defeat after the EU’s top court ruled the iPhone maker must pay €13bn in back taxes, overturning an earlier decision in the Big Tech group’s favor.

To read more go here Subscription Required

Posted on

Forget Tariffs — Fixing ‘America Last’ Tax Policy Would Help More With Offshoring

  • By KImberly A. Clausing

By joining the international tax agreement, the US can move towards a stronger “country by country” minimum tax — which acts as a greater deterrent to tax competition and eliminates the perverse effects of global averaging across high and low tax jurisdictions.

To read more go here Subscription Required

Posted on

Dissecting the U.N. Multilateral Convention Process

  • By Mindy Herzfeld

Mindy Herzfeld examines the progress and prognosis of U.N. efforts to develop a framework convention on international tax cooperation.

To read more go here Subscription Required

Posted on

Foreign Dividend to CFC Ineligible for Dividend Deduction

  • By Andrew Velarde

The IRS has ruled that lower-tier dividends from a specified foreign corporation to a controlled foreign corporation are ineligible for the dividends received deduction, countering arguments that have long been advanced by taxpayers seeking the deduction.

To read more go here Subscription Required

Posted on

Strategic Insights for Global Investors: Unpacking Tax Proposals in India's Union Budget 2024

  • By Anshu Khanna

Anshu Khanna reviews India’s Union Budget 2024 and explains the importance of some key proposals and the effect they could have on the Indian economy and international investors looking to invest in the Indian market.

To read more go here Subscription Required
Back to top