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News Analysis: Fair Digital Taxation: In the Eye of the Beholder
Mindy Herzfeld describes the varying opinions onwhat constitutes fair digital taxation, saying most observers agree that current international tax rules don't properly reflect the realities of today's economy and modes of doing business.
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BEPS Initiatives May Hit Ireland Harder Than Expected
TheOECD's base erosion and profit-shifting initiatives and international tax changes may affect Irish corporate tax revenue over the medium term by more than the ÔøΩ2 billion previously estimated by Ireland'sDepartment of Finance.
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Indonesia Defends Digital Tax Plans Against U.S. Investigation
TheIndonesian governmentintends to implement an electronic transaction tax thatwould take into account consensus on a global approach to modernize corporate tax rules, and remains "open to dialogue" about its plans.
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OECD Aims to Have Global Tax Deal Blueprints Ready in October
Work on global tax reform has advanced to the point that blueprints may be ready by October, setting the stage for agreement after the U.S. election, possibly in 2021, theOECD's tax chief said.
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U.S. to Hit Back at French Digital Tax With New Tariffs in 2021
The U.S.will slap extra 25 percent tariffs on $1.3 billionworth of French goods, including handbags and cosmetics, in retaliation against France's digital services taxÔøΩ but those dutieswill be suspended until January 2021.
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Final FDII Regs Offer Significant Changes to Documentation Rules
Treasuryand theIRShave significantly altered the documentation rules for the foreign-derived intangible income provision in their final regs, relaxing them in some circumstances.
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Pillars 1 and 2: African Perspectives
In this article, the authors examine the key elements of theOECD's proposed two-pillar approach to taxing the digital economy from the perspective of African countries.
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EU Renews Support for OECD Digital Taxation Talks
The EU is committed toworkingwith theOECDto address the issue of digital taxation, according to theEU Council's draft terms of reference for the July 18G-20meeting.
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OECDs CbC Reporting Data Show Ongoing Profit Shifting
Aggregated data collected by the OECD that cover almost 4,000 multinationals' country-by-country report filings suggest that the base erosion and profit-shifting project hasn't yet achieved its goal of aligning profitwith value creation.
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New Gig Economy Rules May Contain Unilateral Measures, OECD Says
NewOECDmodel rules for requiring platform operators likeUberandAirbnbto report data on their sellers to tax administrations contemplate automatic information exchange and implications for indirect and other taxes.
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Trade Spokeswoman Warns Multinationals About Expanded DSTs
Companies that have been exempt under the digital services tax models of theEUand France could find themselves liable under expanded DST regimes being considered by other countries in response to the COVID-19 pandemic.
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U.K. Lower House of Parliament Passes Digital Services Tax
The House of Commons, the lower house ofthe U.K. Parliament, has passed legislation for a controversial digital services tax, bringing it one step closer to becoming law.
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Problems With GLOBE: Scratching the Surface
Mindy Herzfeld looks at potential problemswith OECD pillar 2 arising from differences between financial account and tax system goals in building a global minimum tax base and the separate problem that arises in trying to reconcile these differences.
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Its a matter of fairness: squeezing more tax from multinationals
The cost of the coronavirus crisis means governmentswant to reduce tax avoidance by business.
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Irish finance minister urges EU not to give up on global tax talks
Paschal Donohoe, Ireland's finance minister, haswarned the EU against giving up on a global initiative to extract more tax from digital companies as he makes his pitch to lead the group of eurozone finance ministers.
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Report to Show Digital Tax Deal Near, OECD Official Says
The OECD should be able to unveil a solution in October on new digital taxation rules, showing that jurisdictions are close to an agreement despite recent hiccups.
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Tax Authorities More Open to Audit Negotiation 
Some cash-strapped tax administrations are choosing to close audits and settle disputes instead of pursuing court battles, suggesting that collaborationwill trump confrontation post-pandemic.
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Indias Expanded Equalisation Levy Risks Scaring Away MNEs
India's decision to expand the scope of the equalisation levy risks chasing away multinational enterprises (MNEs) at a timewhen the country is trying to revive the crisis-stricken economy.
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4 Ways COVID-19 Could Impact Global Tax in the Long Term
The economic fallout from the novel coronavirus pandemic is likely to reverberate for years, shifting the international tax landscape as U.S. companies grapplewith losses, legislation and other factors that could complicate planning, including intellectual property placement.
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US Tariff Threats May Harm Alliance, EU Finance Ministers Say
The finance ministers of four European countries havewritten to the U.S. Treasury secretary, saying that threats by the U.S. to impose tariffs in response to national tax policies of other countries may affect future relationshipwith European countries.
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Crisis Recovery Tax Incentives Could Lead to BEPS 3.0
As countries provide incentives to attract foreign investment, the OECD may have to readdress the BEPS framework in the post-COVID future.
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Moving to Formulary Apportionment Could Reduce Long-term TP Risks
Transitioning from the arm's-length principle (ALP) to formulary apportionment could mean fewer risks for taxpayers, but businesses should consider insuring transfer pricing (TP) risks during the transition.
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Lets Build on Cooperation for Digital Tax Deal, OECD Chief Says
Countries should build on the multilateral cooperation that made automatic information exchange possible in order to reach agreement on global corporate tax reform, theOECD's secretary-general told delegates at a key meeting.
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U.K. Parliamentarians Push for Greater Digital Tax Transparency
U.K. lawmakers have proposed several measures to ensure more digital services tax transparency, such as requiring in-scope companies to publish group tax strategies containing country-by-country data.
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Officials Warn 'Grim Future' Awaits Without Digital Tax Deal
If countries can't agree on a common approach to taxing the digital economy, then don't count on theworld to return to the status quo, EU andOECDofficials said.
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Global Tax Deal May Wait for U.S. Election
Countriesworking on an international solution to taxing the digital economy may bewilling towait for the outcome of the U.S. election as they continue talks on a global tax deal, theOECD's tax chief said.
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After the Break Up: Can Europe Build a Better DST?
Robert Goulder examines the U.S.withdrawal from the OECD inclusive framework and possible next steps for the European digital services tax.
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Business Groups Rally Around OECD Global Tax Deal Work
Major business groups again voiced support for OECD-led talks on a global corporate tax reform deal, calling on governments, including the United States, to stay at the negotiating table and quickly reach an agreement.
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OECD Solicits Info on COVID-19 Transfer Pricing Issues
The Organization for Economic Cooperation and Development (OECD) has asked companies and trade associations to comment on the transfer pricing issues they've experienced because of COVID-19.
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Constructive Engagement is Vital for Mutual MNE and Tax Authority Trust
James Karanja, head of the Tax Inspectorswithout Borders (TIWB) Secretariat, tells ITR how multinational enterprises (MNEs) need to adapt as tax administrations gain auditing skills through TIWB initiatives.
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Tax Economists Double Down on Global Tax Multilateralism
International Commission for the Reform of International Corporate Taxation's (ICRICT) Joseph Stiglitz has reemphasized the need for global tax reforms after the US pulled out of digital tax negotiationswith the OECD.
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COVID-19 Challenges for the Arms-Length Principle
In this article, the authors address the implications of the coronavirus pandemic for the arm's-length principle in the context of theOECD's inclusive framework.
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U.S. Withdrawal From Digital Talks Marks Collective Failure
The United States' decision to pull out of international negotiations on taxation of the digital economy has been metwith dismay fromEuropeanfinance ministers.
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U.S. Trade Representative Calls for Broad WTO Reform
The United States has no plans to reverse its stanceregarding the need for significant reform oftheWTO,including a reset of tariff determinations,U.S. Trade RepresentativeRobert Lighthizersaid.
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U.S. Says OECD Talks on Digital Economy Have Hit an Impasse
The United States has told key European countries thatOECDdiscussions regarding a global approach for taxing the digital economy have reached an impasse and thatwashingtonwon't accept even interim changes affecting U.S. technology companies.
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Europeans vow to pursue digital tax plans after US provocation
The EU has defied the US by vowing to pursue its own plans for digital taxes afterwashington pulled out of global negotiations on the matter and threatened to impose tariffs in retaliation against national levies.
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US Upends Global Digital Tax Plans After Pulling Out of Talks with Europe
The US has thrown into disarray plans for a new global tax framework for technology companies after suspending talkswith European countries ÔøΩ andwarning them of retaliatory measures if they press aheadwith their own taxes.
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EU Blacklist May Force Changes in Private Equity Fund Structures
Member states' enactment of measures that target countries on theEU's list of noncooperative tax jurisdictions maywarrant significant changes to the tax planning structures adopted by private equity funds, according to European tax practitioners.
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Groups Urge U.N. Tax Committee to Reconsider OECD Unified Approach
TheU.N.tax committee should aid developing countries seeking tax revenue from the digital economy by rejecting theOECD's unified approach for modernizing corporate tax rules for the digital age, international civil society groups say.
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Making Sense of the New U.K. Global Tariff
Robert Goulder breaks down the U.K. government's post-Brexit trade schedule.
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Economists Launch Global Tax Plan for Pandemic Recovery
COVID-19 economic recovery plans should include a minimum corporate tax rate andwealth taxes, according to a new report,whichwarns against bailouts for tax avoiders and a continued race to the bottom.
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Can the WTO Stop the Race to the Bottom? Tax Competition and the WTO
University of Michigan Law School Professor Martin Vallespinos analyzes the interaction between income tax competition and the multilateral trade regime. He argues that forms of tax competition distort international trade and should be policed. However, he doesn't believe the international tax regimewill be able to cure the ill due to collective action issues. Professor Vallespinos also discusses steps thewTO can take toward modernization to police tax competition measures.
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Design of Scope Limitations for OECD Pillar 1 Work
In thiswhite paper, the author proposes a quantitative method to efficiently limit the scope of multinational enterprises towhich theOECD's pillar 1 amount A reallocationwould apply.
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OECD Wants Taxpayer Input on COVID-19 Transfer Pricing Issues
In a questionnaire issued to business group members, theOECDhas called for taxpayers to explain the transfer pricing compliance challenges caused by the COVID-19 crisis and to identify any issues that require clearer guidance.
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Beyond Digital: Is Cryptocurrency the Next Tax Frontier?
Mindy Herzfeld examines the paucity of IRS guidance on digital currency and the confusion that creates.
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Global Tax Talks Waver as Pandemic Hits Government Coffers
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Insight: Covid-19 and the Future of TaxationWhat Role for Cooperative Compliance?
The author suggests that the disruption caused by Covid-19 may provide an opportunity to adjust theways inwhich multinational enterprises and tax administrations interact, by the use of cooperative compliance programs.
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Insight: U.S. Investigation of Digital Services TaxesWill It Affect Multilateral Negotiations at OECD?
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U.S. Blocking Digital Tax Agreement at OECD, Le Maire Says 
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Trump Administration Escalates Global Fight Over Taxing Tech