Int'l Tax News

The U.K. digital services tax might be in effect, but it should be suspended to give companies grapplingwith the COVID-19 crisis some relief, a tech trade group representative said.

Multinational businesseswith prior years' deemed repatriation income maywant to take advantage of the special net operating loss carryback rules in the coronavirus stimulus package, a practitioner says.

Two more industry groups are dialing up the volume on calls to their respective governments to delay the timeline of theOECD'swork on a global corporate tax overhaul in light of the coronavirus pandemic.

Not all taxpayerswillwant to take advantage of the changes to the interest deduction limitation in the latest round of coronavirus legislation, according to a practitioner.

The U.K. tax authority began seeking public input on a proposed rule to require large businesses to notify itwhen taking an uncertain tax position they believewill be challenged.

HM Revenue & Customs issued a consultation to determinewhether new rules meant to prevent companies from manipulating differences in national tax systems may hit some legitimate lending relationships.

The U.K. government published guidance to help multinational companies navigate placeswhere the country's digital services tax interactswith other corporate tax measures, including transfer pricing rules and similar digital levies overseas.

Tax officials from around theworld face immense pressure to negotiate an overhaul of the international tax system at the OECD by the end of the year, even as the coronavirus pandemic brings mostwork around theworld to a halt.

Taxpayers are having to go to "extreme lengths" to claim the foreign derived intangible income (FDII) deduction under US tax rules. One tax director at a medical device company talks to ITR about the challenges.

A Swedish court has ruled against thermal camera producerFLIR Systemsin a dispute concerning an intangible transfer to a Belgian branch, holding that the tax agency correctly denied a group subsidiary's notional tax deduction.

Nonresident e-commerce operatorswill now have to pay a 2 percent tax on revenues from the sale of goods and services to Indian consumers, after the government broadened the scope of its equalization levy regime.

Practitioners are discovering that business-friendly changes to net operating losses and interest deduction limitations in legislation responding to the coronavirus economic crisis could also adversely affect multinationals because of interactionswith other international provisions.

Mindy Herzfeld examines U.S. Treasury options for alleviating the economic blowback of the coronavirus pandemic, questioningwhether further relief has been left on the table.

In this article, the authors discuss newly introduced research and development tax incentives in Germany, focusing on eligibility requirements, determination of tax relief, and international cooperation.

Payments to an Australian company for supplies of software services do not qualify as fees for technical services but should be further examined to determine if they qualify as royalties, theDelhi High Courtheld.

Prime MinisterMikhailMishustin said Russia maywithdraw from its tax treatieswith specific countries that refuse to impose a 15 percent tax on individuals transferring their dividend income abroad.

Treasuryshould postpone theOECD'swork on updating global corporate tax rules for the digital age as companies and governments continue grapplingwith the economic fallout of the coronavirus crisis, a major trade group said.

In this article, Eric M. Lopata of Prudential Financial Inc. explainswhy a net operating loss carryback provision in the COVID-19 relief legislationwill not have the intended stimulus effect unless Congress also addresses a problem caused by the application of the NOL computation rules to taxpayerswith global intangible low-taxed income.

India has announced relief measures thatwill extend the filing deadline for income tax and goods and services tax returns, provide relief under the tax dispute scheme, and lower interest rates fordelayed tax payments.

TheOECDhas outlined emergency tax measures that governments can adopt to respond immediately to the economic fallout of the coronavirus pandemic, sending a clear message: Dowhatever you can now to keep taxpayers afloat.

AnAustralian Senatecommittee is considering legislation to reform research and development tax initiatives that critics say islargely unchanged from a set of measures that failed to passwhen first proposed in 2018.

The Supreme Court of Canadahas dismissed an appeal byAmazon Inc., a major victory for customerswho claim the company charged sales taxes thatweren't due.

Buried deep in the pages of aSenatebill to provide economic relief from the coronavirus pandemic are long-awaited Tax Cuts and Jobs Act technical corrections on transition tax overpayment and downward attribution.

The OECD has outlined several tax measures that countries can take to respond immediately to the economic fallout of the coronavirus pandemicwith a clear message to governments: Dowhat you can to help taxpayers.

AsHM Revenue & Customsprepares to implement a series of new measures targeting tax avoidance schemes, the agency has signaled its openness to amending aspects of the hybrid mismatch rules criticized as disproportionate and overbroad.

In this article, the authors discuss how the digitalization of the economy is affecting nexus rules and analyze international tax treaty law on permanent establishment and the taxable presence of digital businesses.

Despite the growing coronavirus pandemic, theOECDsecretariat is stillworking "full steam" ahead on a solution to update the international tax rules for the 21st century ÔøΩwhile using digital methods.

TheEuropean Commissionhas proposed thatbusinesses affected by the coronavirus be allowed to receive direct grants and selective tax advantages of up to ÔøΩ500,000 to address urgent liquidity issues.

Over 20 U.S. trade groups are calling on the Trump administration to eliminatesection 301tariffs, saying it is the onlyway to provide immediate relief from the financial burden of the coronavirus.

Three of theBig Four accounting firmshave added to calls forthe Supreme Courtto reviewAltera, arguing in an amici brief that the commensuratewith income standard cannot justify the 2003 cost-sharing regulations.

Irish tax revenues reached their highest level last year at approximately ÔøΩ60 billion, but theOECD's international tax proposalswill increase uncertainty and volatility in corporation tax receipts in the coming years.

Citing a $5 billion increase in aggregate tax liability following theNinth Circuit'sAlteradecision,Cisco Systemsand other high-profile tech companies have filed an amici brief supportingAltera's petition forSupreme Courtreview.

Using the coronavirus pandemic as a backdrop, Mindy Herzfeld reviews legislative and administrative actions during and since the 2008 financial crisis, noting that antiabuse tax ruleswritten in times of global profit and economic growth can have adverse effects in a downturn.

As the coronavirus extends its potentially deadly reach throughout theworld, severalcountries have announced tax and other measures to mitigate the economic impact from theCOVID-19disease.

An advisory forum to thePolish Ministry of Financehas recommended that the country's new rules on transfer pricing methods be applied in accordancewithOECDguidance on the transactional net margin and resale-price methods.

The capital gains tax entrepreneurs' relief is expensive, ineffective, and unfair, U.K. Chancellor of the ExchequerRishi Sunakdeclared as he announced a substantial reduction in the lifetime limitwith immediate effect.

ProfessorsJordan M. Barry and Ariel Jurow Kleiman discuss the development of the income tax limit to the foreign tax credit before describing the implementation and conceptual problemswith such a limit. They continue on to consider the arguments in favor of a narrow tax credit, before finally presenting the reform options for policymakers. Barry and Kleinman ultimately conclude that movingforward involves abandoning the credit's sharp, arbitrary distinction between pure income taxes and all other taxes.

The U.K. government is maintaining its commitment to introduce a digital services tax in threeweeks.

Business groups and companies including AstraZeneca are pushing back against calls from U.S. lawmakers and advocacy groups to make corporate global tax reports public,warning that publishing such data could harm them.

The author discusses how he believes the OECD's proposals under Pillars One and Two to increase corporate tax globally conflictwith the organization's recently issued economic assessment of the impact of the coronavirus on theworld economy.

The government saidwednesday itwas looking forways to boost the attractiveness of the U.K. as a place for fund managers to establish themselves, including removing tax barriers that hold companies back from setting up.

More than 3,200 companies reported approximately $140 billion in tax obligations during 2017 related to the Tax Cuts and Jobs Act's transition tax provision, the Internal Revenue Service has reported.

If the OECD adopts suggestions to align country-by-country reporting (CbCR)with the Global Reporting Initiative (GRI) standard public CbCRwill be inevitable, but this did not stop organisations expressing their opinions.

The European Commission onwednesday asked for comments over the next fourweeks on an action plan to fight tax fraud as it prepares to make a more definite announcement in the summer.

The U.S. and Mexican tax authorities have renewed their agreement on a framework allowing more than 650 manufacturing companies to obtain certainty from the Mexican government about their taxes, an Internal Revenue Service official said Thursday.

As Brazil embraces OECD standards, many countries are moving in the opposite direction. This seismic shift in the largest South American economy could mean that Brazilwill remain an outlier in global tax policy.

The US technology company is battling against the European Commission's finding that its past cost-sharing arrangements in Luxembourg violated EU state aid law.

Robert Goulder examines the EU state aid case against Fiat and the implications it holds for Apple.

The financial and legal issues at stake inAltera Corp.'s cost-sharing challenge are too great forthe Supreme Courttowait for a circuit split, according to a group of trade and industry organizations.

TheOECDhas called off an upcoming public consultation on its review of its country-by-country reporting standards under action 13 of the base erosion and profit-shifting project, citing growing coronavirus concerns.