Int'l Tax News

Senate appropriators approved a bill that would fully fund U.S. contributions to the OECD while Republican taxwriters in the chamber formally voiced their opposition to the organization’s two-pillar global tax deal.

Vincent Ooi and Kerrie Sadiq examine the Australian Taxation Office’s reasoning for adopting a broad interpretation of royalties amidst various criticisms suggesting it has gone too far and is out of step with internationally accepted principles.

The Indian government hopes for agreement on the OECD’s pillar 1 tax reform plan, but it can’t give its support unless its interests are taken into account, a top finance ministry official reportedly said.

Xiaoli Ortega examines research and analyses conducted by the Chinese government, professionals, and scholars regarding how China may respond to pillar 2.

User data, from which tech companies derive superprofits, could be akin to a new natural resource and could be taxed globally as such, according to Norwegian Finance Minister Trygve Slagsvold Vedum.

Reuven S. Avi-Yonah reflects on the relationship between investment incentives and the possible neutralization of pillar 2 effects.

The Indian government has proposed abolishing its controversial 2 percent equalization levy to help advance the OECD-brokered two-pillar global tax reform plan, Indian Finance Minister Nirmala Sitharaman said.

The Indian government plans to eliminate a highly controversial so-called angel tax on startup investments for all investors and to reduce the corporate tax rate for foreign companies by 5 percentage points.

The latest draft setting out terms of reference for a U.N. framework convention on international tax cooperation does not account for EU concerns that early protocols should be negotiated separately from the convention.

Robert Goulder comments on the Labour Party’s victory and the rise of Chancellor of the Exchequer Rachel Reeves.

In news analysis, Lee A. Sheppard examines inversions from the perspective of closely held business owners attempting to restructure their corporate entities to escape the effects of political instability.

The OECD has released a package of pre-application templates to assist multinational groups with their international compliance assurance program applications, which must contain specific information and overviews of transactions.

The OECD is already eyeing other pressing profit attribution issues, including those related to global mobility, now that only minor items for a mandatory amount B still need to be negotiated, an OECD official has said.

A corporate proposal for a permanent country-by-country reporting safe harbor under the pillar 2 global anti-base-erosion rules could help make the EU more business friendly, according to a European Commission official.

The OECD is working on identifying jurisdictions that are planning on adopting the optional amount B transfer pricing simplification framework and will likely release a list in October, an OECD official said.

The European Commission’s tax decluttering and pro-competitiveness agenda will probably enhance its business-friendly image and build a bridge between pillar 2 and the anti-tax-avoidance directive, an EU official said.

Multinational enterprises may have reduced their base erosion and profit-shifting activity in the past few years, but the practice is still ongoing, according to the most recent country-by-country reporting data.

Three multinational music streaming companies have mounted a challenge to a Canadian streaming services tax in federal court, according to a digital music advocacy group that claims the levy is bad policy.

The European Parliament’s political groups have decided that a member of the Left Group will succeed Paul Tang as chair of the EP’s subcommittee on tax matters.

Hong Kong’s government has gazetted legislation establishing a patent box granting preferential tax treatment for qualifying income from intellectual property and IT.

In this symposium paper, the UF Tax Incubator working group examines the U.S. approach to taxing income earned through foreign branches, and it explores ongoing issues and potential reforms.

Business groups are sounding the alarm on potential trade and economic damage from Canada’s digital services tax following the issuance of a coming-into-force order by the Canadian government.

Robert Goulder comments on the new EU tariffs directed at Chinese EVs.

The view that low taxation increases investment is evolving, according to the European Commission, raising the question whether corporate tax can influence EU countries' competitiveness.

Netflix, Walt Disney, and other U.S. streaming companies have asked a Canadian court to stop plans by authorities to force them to fork over 5% of their sales in the country to finance local broadcast news and other domestic content.

Canada authorized the implementation of a digital-services tax, a move that threatens to trigger trade retaliation from Congress and the Biden administration.

Nana Ama Sarfo reviews the latest research commissioned by the South Centre, African Union, African Tax Administration Forum, and West African Tax Administration Forum into the amount of revenue developing countries might raise from amount A versus a digital services tax.

Introducing a global minimum tax rate for the largest multinational enterprises is a “catastrophic failure” because it burdens businesses and dampens EU competitiveness, according to Hungarian Prime Minister Viktor Orbán.

The end-of-June deadline for countries to conclude pillar 1 tax reform negotiations has come and gone, but delegates are still making good headway toward a final agreement, the OECD’s tax director said.

India has joined the group of countries that have extended the “unilateral measures compromise” with the United States that outlines a transitional approach to their digital services taxes before pillar 1 rules are implemented.

Nathan Boidman, Michael N. Kandev, and Marc André Gaudreau Duval, in the first installment of a two-part analysis, provide an overview of, and context for, the Global Minimum Tax Act — legislation now moving through Canada’s Parliament to implement pillar 2. Part two will more closely examine certain aspects of the legislation with a focus on provisions that yield interpretational issues or deal with antiavoidance.

Hafiz Choudhury explains efforts at the U.N. to foster an international taxation cooperation process more inclusive of developing countries. The opinions expressed in this article are solely those of the author and do not reflect the views of any other person or organization, in particular the U.N.

Aditi Goyal and Kanupriya Sharma explore the concept of “virtual permanent establishment” as a framework for taxation in an increasingly digital world, using the Clifford Chance case in India as a primary example.

More OECD focus on developing permanent safe harbors for pillar 2 minimum tax rules could decrease the need and volume of administrative guidance going forward, according to an OECD tax official.

High-income countries should engage constructively in U.N. discussions to develop a framework convention on international tax cooperation or risk a global spread of tension in tax policymaking, a top EU tax official said.

The U.S. is set on making Amount B, which deals with companies’ marketing and distribution activities, mandatory even as several other countries are pushing to make it optional.

The Canadian Parliament has passed a highly controversial 3 percent digital services tax on large businesses, sparking calls from U.S. trade groups for Canada to reconsider.

Policymakers have spent more than a decade crafting an international consensus on the allocation of corporate tax revenue, but the scattered landscape for settling tax cases could undermine the goal of a smoothly operating system.

The dispute, which was closely watched by experts, involved a one-time foreign income tax, but many saw it as a broader challenge to pre-emptively block Congress from passing a wealth tax.

The court rejected a challenge from conservative activists to a one-time tax on certain foreign investments but left unresolved questions about whether some leading Democratic revenue-raising ideas are constitutional.

Mindy Herzfeld examines what countries are doing to maintain competitiveness as pillar 2 makes offering fiscal incentives a fraught undertaking.

The leaders of the G7 countries are aiming to open the pillar 1 multilateral convention for signature by the end of June.

Young Ran (Christine) Kim with Cardozo School of Law and Darien Shanske with the University of California, Davis, continue their argument that a digital barter tax is a good idea and examine possible legal arguments and challenges.

Turkish lawmakers have drafted new tax proposals aimed mostly at companies, seeking to repair a budget buffeted by last year’s earthquakes, in what would be the biggest overhaul in a generation.

Norway’s planned clampdown on the nation’s wealthiest citizens is provoking a backlash from entrepreneurs who warn the measure will just worsen the economy’s heavy dependence on oil and gas.

In a communique at their summit in Italy, the G-7 leaders said they hope the treaty will be open for signature by the end of June, as OECD officials have said. The G-7 leaders also called for further progress on the implementation of the OECD’s global minimum tax.

Turkish Finance Minister Mehmet Simsek said the government has postponed plans to introduce a “very limited” transaction tax on stock trading, after push back from traders.

Sir Keir Starmer, UK opposition party leader, set out plans to raise £8.6bn in tax in the Labour manifesto on Thursday as he promised to “relight the fires” of economic growth and bring “Conservative chaos” to an end.

The Danish government presents a plan to significantly lower taxes for entrepreneurs, in a move to bolster the startup scene in the Nordic country, particularly in the biotech industry.

Saudi Arabia laid out a series of steps it plans to take to boost its debt capital market, including a possible easing in taxes it hopes will make local corporate bonds more appealing to foreign investors.