Int'l Tax News

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.

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.

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.

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.

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.

Treasuryand theIRShave significantly altered the documentation rules for the foreign-derived intangible income provision in their final regs, relaxing them in some circumstances.

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.

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.

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.

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.

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.

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.

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.

The cost of the coronavirus crisis means governmentswant to reduce tax avoidance by business.

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.

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.

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.

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.

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.

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.

As countries provide incentives to attract foreign investment, the OECD may have to readdress the BEPS framework in the post-COVID future.

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.

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.

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.

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.

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.

Robert Goulder examines the U.S.withdrawal from the OECD inclusive framework and possible next steps for the European digital services tax.

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.

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.

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.

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.

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.

The United States' decision to pull out of international negotiations on taxation of the digital economy has been metwith dismay fromEuropeanfinance ministers.

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.

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.

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.

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.

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.

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.

Robert Goulder breaks down the U.K. government's post-Brexit trade schedule.

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.

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.

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.

Mindy Herzfeld examines the paucity of IRS guidance on digital currency and the confusion that creates.