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Int'l Tax News

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Belgium to Resume Digital Tax Discussions

  • By Elodie Lamer

Belgian members of Parliament on June 2will discuss a new proposal to introduce a digital tax at the national level.

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Economic Analysis: Monetizing NOLs During a Recession

  • By Martin A. Sullivan

In economic analysis, Martin A. Sullivan examines refunds for losses, especially in light of the coronavirus pandemic.

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Corporate Tax in the New Normal

  • By Mindy Herzfeld

Mindy Herzfeld describes changes in perceptions of corporate taxes and the concept of a corporation that could result from the coronavirus pandemic.

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Clarifying Subpart F and GILTI Inclusions for Indirect and Deemed Paid Taxes

  • By Carrie Brandon Elliot

Carrie Elliot reviews the new rules for computing deemed paid foreign taxes on income contributing to subpart F or global intangible low-taxed income inclusions.

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US Looking Into Tariffs Against India, EU Over Digital Taxes

  • By Alex M. Parker

The U.S. Trade Representative's Office announced Tuesday itwas imitating investigations into India and other countries, aswell as the European Union, that have enacted or are considering special taxes on digital services.

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US Fires Warning Shots on DTSs

  • By Mattias Cruz Cano

The US has announced that itwill begin an investigation into digital services taxes (DSTs) that have been adopted or are being considered, alluding to a more aggressive response to unilateral action.

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Digital Taxes Face International Legal Gantlet

  • By Alex M. Parker

Special taxes on digital companies seem almost inevitable as the novel pandemic heightens focus on the tech sector, but they could face legal challenges under both international trade and tax rules as countries begin to collect.

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Tax Incentives May Not Spur US Operations in Virus Fight

  • By Natalie Olivo

The novel coronavirus pandemic has some members of Congress discussing tax policies that could entice multinationals to bring manufacturing home, but those measures, including a slash in the corporate rate, may not make much difference in the current uncertain climate.

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Business Consider Renegotiating APAs for an Exit Strategy

  • By Danish Mehboob

Tax directors intend to revise force majeure clauses in advanced pricing agreements (APAs) and inter-company contracts after finding limited certainty on deferring certain contractual obligations and maintaining agreements under the clause amid the pandemic.

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New Taxes Could Pay for EC's $750 Billion Recovery Plan

  • By Mattias Cruz Cano

The European Commission (EC) has proposed a recovery plan for the EU to tackle COVID-19 through a fundworth ÔøΩ750 billion ($825 billion),which could be paid for by new taxes.

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Report Urges Swift EU-U.S. Border Tax Talks to Avoid Trade War

  • By Annagabriella Colon

The United States and the EU should begin talks about a proposed carbon border tax soon to avert a potential tradewar, a new report from theAtlantic Councilwarns.

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EU to Propose Minimum Corporate Tax if OECD Cant Get Consensus

  • By Sarah Paez

If countries fail to reach a deal on global minimum corporate taxation this year, theEuropean Commissionwill propose its own plan by next year, EU Tax CommissionerPaolo Gentilonisaid.

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Proposed Brazilian Digital Tax Faces Uncertain Fate in Congress

  • By William Hoke

Brazil'sHouse of Representativesis considering legislation to subject awide range of digital activities to progressive taxation. The proposal faces an uncertain future in theNational Congressand possible opposition by the United States.

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ATO Targets Mischaracterization in Foreign Investment Structure

  • By Ryan Finley

TheAustralian Taxation Officesaid itwill be closely scrutinizing tax structures used by nonresidents to invest in domestic businesses ÔøΩ particularly their characterization of income and the form of their investment interests.

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Driving to Certainty Under Pillar 1

  • By Francois Chadwick

In this article, the author proposes a framework for developing administrableOECDpillar 1 rules that promote a consensus solution to the taxation of the digital economy by addressing the risk of uncertainty for taxpayers.

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Home Office is PE Under Denmark-Germany Tax Treaty, Board Holds

  • By Annagabriella Colon

A German employee's home office in Denmark constitutes a taxable permanent establishment, the Danish Tax Board has ruled, clearing theway for taxation of the German employer.

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OECD Chief Warns of Messy Outcome Without Digital Tax Deal

  • By Stephanie Soong Johnston

If there is no globally agreed solution to tax the digital economy, then dozens of debt-laden countrieswill move unilaterally, raising the risk of tradewars during the coronavirus pandemic, theOECD's chiefwarned.

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Mexicos Digital Services Tax Regime

  • By Valentin Ibarra and Jorge Ramon Galland

In this article, the authors discuss Mexico's new regime for taxing digital services that takes effect June 1, including the obligations it places on both resident and nonresident digital platforms and digital intermediaries that provide services to residents of Mexico.

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How Would Digital Tax Reform Affect the Cross-Border Marketplace?


In this article, the author discusses how theOECDandG-20digital tax reformswould affect marketplaces, especially marketplaceswith China-related inbound and outbound investments.

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Telecom Trade Groups Urge Caution Over Unilateral European DSTs

  • By William Hoke

Two associations representing telecommunications and mobile network operators said European countries'plans to introduce unilateral digital services taxeswill increase double taxation disputes and result in more complexity.

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Economic Fears Deepen as US Escalates Tensions With China

  • By Niv Elis

Increased tensions between President Trump and China over the coronavirus pandemic are threatening to complicate a recovery from theworst global economic downturn in decades.

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COVID-19 Saps US Trade Threat on Digital Taxes: OECD Official 

  • By Alex M. Parket

The coronavirus downturn in trade has taken "some of the teeth" out of the U.S. threat to impose sanctions on countries that enact a digital services tax, a top official for the Organization for Economic Cooperation and Development said Thursday.

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China Unveils $631B in Pandemic-Fighting Tax Cuts

  • By Joseph Boris¬†

China plans new tax cutsworth $4.5 trillion yuan ($631 billion)while forgoing economic growth forecasts, the country's No. 2-ranking official said in a key policy speech Friday that touted measures to rescuer the country's economy from the COVID-19 pandemic.

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Indonesia Plans 10% VAT On Foreign Digital Cos. Amid Virus

  • By Joseph Boris

Indonesiawill hit foreign companies' sales of digital products and services in the countrywith a 10% value-added tax starting July 1 to help pay costs of the COVID-19 pandemic, the government said.

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The Société Générale Decision: Building the Perfect FTT

  • By Robert Goulder

Robert Goulder examines the CJEU's recent decision upholding the validity of Italy's financial transaction tax.

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Survey Shows British Support for COVID-19 Windfall Tax

  • By Andrew Goodall

More than half of voters in Great Britainwould support an excess profits tax on companies realizing profits "significantly above their normal levels" during the coronavirus pandemic, according to a YouGov survey.

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Transfer Pricing Faces Challenges in COVID-19 Era

  • By Ryan Finley

The expected spike in the number of multinationals that report losses in thewake of the COVID-19 pandemic may seriously disrupt an international transfer pricing regime thatwas designed primarily for the allocation of profit.

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France Still Postponing DST in 2020, Contrary to Reports

  • By Stephanie Soong Johnston

Contrary to media reports, France hasn't changed its plans to suspend digital services tax collection in 2020 and still supports OECD-level negotiations on a common approach to modernizing international tax rules for the digital age.

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An Off-Ramp for the OECDs Digital Tax Project

  • By Mindy Herzfeld

Mindy Herzfeld discusses the U.S. role ÔøΩ or lack thereof ÔøΩ in the OECD project to address digital taxation,which she says lacks a reasonable deadline and reliable data.

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Trump Talks New Taxes for Companies With Overseas Production

  • By Alexis Gravely

Businesses that manufacture products internationally could face new taxes in an effort byPresident Trumpto bring more production to the United States.

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OECD Chief Warns Coronavirus Debt Will "come back to haunt us"

  • By Niv Ellis

Organization for Economic Cooperation and Development Secretary-General Angel Gurría onwednesdaywarned that the debt countries and companies take on toweather the coronavirus pandemicwould be a drag on economies in the future.The debt, he said,would "come back to haunt us," according to the Financial Times,which hosted the online conferencewhere Gurría made the remarks.

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UK Lawmakers Call For Denying Virus Aid To Tax Haven Cos.

  • By Matt Thompson

The U.K. should base relief given to companies during the coronavirus pandemic on good behavior, denying funds and tax breaks to those doing business in tax havens, a cross-party group of legislators said in a letter released. The letter, dated Thursday, asked Rishi Sunak, the chancellor of the Exchequer, to place conditions on big businesses receiving state aid, such as not being registered in a tax haven, imposing a moratorium on dividends and share buybacks, and curbing excessive executive pay

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Cos. Caution OECD Not To Expand Tax Reporting Mandate

  • By Joseph Boris

Multinational companieswould be unduly burdened if the Organization for Economic Cooperation and Development expands its requirement for how they report jurisdiction-specific data about tax activities, several corporate executives saidwednesday.

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UK Will Raise Taxes to Pay for COVID-19 Spending

  • By Mattias Cruz Cano

The UK government is set to increase taxes as part of its plans to finance the emergency COVID-19 spending, signalling that even business-friendly jurisdictionswill be leftwith no other choices to strengthen budgets.

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Big Businesses and NGOs find common ground on CbCR data

  • By Josh White

The OECD's May 12-13 meeting on country-by-country reporting (CbCR) saw businesses and campaign groups find some agreement on the limits of aggregate data compared to consolidated data.

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Polish Subsidiary Is Not a Permanent Establishment, CJEU Says

  • By Kiarra M. Strocko

Just because a non-EU company has a subsidiary in a member state does not mean the company has a permanent establishment in the EU, theCourt of Justice of the European Unionheld.

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Germanys License Barrier Rule and Its Application of the Nexus Approach for Preferential Tax Regimes


In this article, the authors examine the implementation of Germany's license barrier rule and the guidance that theGerman Ministry of Financerecently provided regarding the compliance of preferential tax regimeswith the nexus rule.

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The OECD Dives Into Cash Pools

  • By Stefanie Perrella and Beau Sheil

In this article, the authors examine how tax advisers can structure cash pools such that intercompany interest rates are best positioned towithstand review based on theOECD's new transfer pricing guidance on financial transactions.

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Developing Countries Want Equal Participation in OECD Proposals

  • By Kiarra M. Strocko

Developing countries are seeking an international legal instrument that dealswith tax avoidance and data transparency in a neutral and fairway,whichwould include giving them an equal voice in global digital tax initiatives.

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U.K. Blocking OECD From Posting Aggregated CbC Reporting Data

  • By Stephanie Soong Johnston

The U.K. governmentwon't agree to theOECD's publication of aggregated country-by-country reporting data under action 13 of the base erosion and profit-shifting project unless "data quality and consistency issues" are addressed.

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OECD Postpones Key Meeting of Global Tax Overhaul Project

  • By Stephanie Soong Johnston

Nearly 140 countries thatwere planning to meet in July to try reaching political consensus on a proposed global corporate tax overhaulwill now meet in early October because of the coronavirus crisis.

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Its Time for Pillar 3: A Global Excess Profits Tax for COVID-19 and Beyond

  • By Allison Christians and Tarcisio Diniz Magalhaes

In this article, the authors consider proposals to rebuild revenue coffers using excess profits taxes during the COVID-19 pandemic and argue that, owing to emerging global tax data, norms, and governance structures, a global excess profits tax has better prospects than a series of unilateral measures.

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So Many Ways to Lose Your Losses

  • By Mindy Herzfeld

The U.S. income tax ÔøΩ like all others ÔøΩ is supposed to allow for an offset of economic losses against gains so that taxpayers are taxed only on their net income. For the same reason, expenses incurred in generating revenue are supposed to reduce gross income in calculating net income.But it doesn't alwayswork thatway in the case of foreign income includible in the US tax base, and the CARES Act didn't help matters.

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What the CJEUs Hungarian Cases Mean for Digital Taxes

  • By Ruth Mason

In this article, the author discusses theCourt of Justice of the European Union's recentTescoandVodafonejudgments and their implications for potential challenges to European digital taxes.

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Hungary to Offer Full Exemption for Reinvested Profits

  • By Sarah Paez

As part of a coronavirus mitigation package, Hungarywill offer companies that pledge to reinvest in Hungary over the next four years a full exemption on reinvested profits.

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Poland to Update COVID-19 Relief Package With Netflix Tax

  • By Annagabriella Colon

The Polish government plans to chargeNetflix,Amazon, Apple TV+, and other large video-on-demand service providers a 1.5 percent fee to assist the country's film industry,which has been stalled by the COVID-19 pandemic.

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Italian Financial Transaction Tax Does Not Violate EU Law

  • By Kiarra M. Strocko

Charging a tax on financial transactions involving derivatives trading that applies regardless of the market participants' and intermediaries' residence does not constitute a restriction on thefree movement of capital, the EU's highest court held.

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Tax Researchers Chide OECD Digital Tax Push Amid Pandemic

  • By Joseph Boris

Joseph Boris

Work toward a global tax on corporations' digital operations should be suspended so that countries can devote time and resources to rebuilding their economies from the coronavirus pandemic, two tax policy researchers said in a new study.For the Organization for Economic Cooperation and Development, "nowwould be a good time to hit the pause button" on the negotiations, Scott Hodge and Daniel Bunn of the Tax Foundation said in research published Monday. They recommended that the talkswait until the global economy has returned to stabilitywith 2% annual growth for two consecutive years.

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Uber, Booking.com Wary About OECDs Gig-Work Tax Rules

  • By Joseph Boris

Joseph Boris

Ride-hailing service Uber'swariness over acting as a tax data middleman, alongwith travel search engine Booking.com's concern about privacy-law compliance, highlighted comments the OECD saidwednesday it has received through its project to reshape tax rules for the gig economy.

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EU Sticking To Corp. Tax Reform Timetable Despite Crisis

  • By Todd Buell

Todd Buell

The European Commission believes that efforts to reform corporate taxation aswell aswork to combat tax fraud are essential tasks, and therefore theywill continue as planned despite the COVID-19 pandemic, according to a draft document seen by Law360.The EU's executive arm plans to issue a communication on fighting tax evasion, according to a draft document. The commission is planning to stick to a timetable, set earlier this year, to issue a communication thatwould involve the tax challenges of moving to digital technology. It also plans to issue another in this quarter on fighting tax evasion, according to the text of a draftwork program.

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