Skip to main content

Int'l Tax News

Posted on

A Case for Higher Corporate Tax Rates 

  • By Edward Fox and Zachary Liscow

The authors offer reasons to favor a higher rate and describe reforms that could help ease the adoption of efficient, higher taxes on corporate returns. They suggest that, at minimum, proponents of lower corporate tax rates present an incomplete picture and that the "lower corporate tax rates" conclusion is a non-obvious one.

To read more go here

Posted on

EU to Pursue Tax Overhaul if OECD Global Tax Rewrite Fails

  • By Hamza Ali

The EU may try to harmonize corporate tax collection under a single set of rules if OECD-led talks to rewrite global tax rules fail, the bloc's tax commissioner said.

To read more go here Subscription Required

Posted on

Insight: Are You on the OECD Pillar One Black List? The Winding Road Ahead 

  • By Glenn DeSouza

The OECD recently released a "blacklist" of industries thatwould be subject to a tax on global profit due to market intangibles, the author looks at the blacklist model, the U.S. reaction, opportunities for companies on the "whitelist," and theworkstreams to address controversial areas.

To read more go here Subscription Required

Posted on

U.S. Envoy Calls Unilateral Digital Taxes Self-Destructive 

  • By Isabel Gottlieb and Jan Stojaspal

The U.S. ambassador to Poland called unilateral plans to levy digital taxes on large tech companies "self-destructive" in an op-ed piece published March 1 by Rzeczpospolita, a major Polish daily.

To read more go here Subscription Required

Posted on

Real Effects of Private Country-by-Country Disclosure

  • By Lisa De Simone and Marcel Olbert

Lisa De Simone and Marcel Olbert investigate the effects of mandatory private Country-by-Country disclosure to tax authorities on economic activity.They find evidence that firms affected by the disclosure mandate reduce ownership in tax haven subsidiaries relative to unaffected firms and increase their organizational transparency. They also observe that affected firms increasingly allocate revenue, employment, total assets, and, correspondingly, tax payments to subsidiaries in low-tax European countries.De Simone and Olbert concludethat mandatory CbC disclosure curbs the most aggressive tax planning achieved through tax haven operations but also affects the allocation of multinationals' real economic activities.

To read more go here

Posted on

Financial Transparency to the Rescue: Effects of Country-by-Country Reporting in the EU Banking Sector on Tax Avoidance 

  • By Michael Overesch and Hubertus Wolff

Michael Overesch and Hubertuswolff analyze the effect of mandatory financial transparency on corporate tax avoidance. Their findings indicate that multinational banks increased their tax expense relative to other banks unaffected by the Country-by-Country Reporting mandate. Moreover, the authors found a stronger response by banks thatwere particularly exposed to the new transparency due to significant activities in tax havens. Overesch andwolff conclude that their results suggest that Country-by-Country Reporting can serve as an additional instrument for policymakers to curb corporate tax avoidance.

To read more go here

Posted on

Unintended Consequences of Eliminating Tax Havens

  • By Juan Carlos Su√°rez Serrato

By:Juan Carlos Suárez Serrato

Juan Carlos Suárez Serratostudied a policy that limited profit shifting by US multinationals and shows it raised the tax cost of domestic investment. His research indicates that firms affected by the policy responded by reducing investment and domestic employment. Further, firm-level responseswere amplified to local labor markets through the established networks of profit-shifting firms; more exposed local labor markets experienced declines in employment, income, and home values and saw increases in government transfers. The author concludes that policy proposals that limit profit shifting should consider effects on economic activity in addition to tax revenue.

To read more go here

Posted on

Door Closed for New Companies to Join OECD Tax Compliance Pilot 

  • By Isabel Gottlieb

The OECD's second round of a pilot risk assessment programwon't accept more companies, for now, an IRS official said. The organization may, however, try to grow the program gradually in the future, Jennifer Best, director of the treaty and transfer pricing operations at the IRS's Large Business and International Division, said Thursday.

To read more go here Subscription Required

Posted on

EU Critical of Ireland, Others on Tax Avoidance Crackdown 

  • By Hamza Ali

A handful of EU countries haven't made enough progress over the last year in tackling tax avoidance strategies used by multinational companies, the European Commission said in a package of annual reports.

To read more go here Subscription Required

Posted on

AI Comes to the Tax Code 

  • By Richard Rubin

Governments are increasingly relying on machine learning and data analytics to analyze troves of data as they seek to detect tax evasion, respond to taxpayers' questions and make themselves more efficient.

To read more go here Subscription Required

Posted on

EU Antitrust Chief Defends Countries Digital Tax Measures 

  • By Hamza Ali and Aoife White

EU antitrust and tech chief Margrethe Vestager defended European nations' plans to impose their own digital services taxes on large tech firms.

To read more go here Subscription Required

Posted on

U.K. Bound By EU State Aid Decisions Post-Brexit, Vestager Says 

  • By Hamza Ali and Aoife White Teaser

The U.K. tax authority must complywith a 2019 EU decision on state aid even if EU rules stop applyingwhen the Brexit transition period ends, the EU's competition czar said.

To read more go here Subscription Required

Posted on

Some Countries Move on Digital Taxes Despite Talks, U.S. Threats 

  • By Hamza Ali

A handful of countries have already imposed or plan to levy digital taxes on large tech companies over the next year or so, even as the OECD tries to get them to unite under a common approach.
To read more go here Subscription Required

Posted on

Insight: New OECD Guidance on Transfer Pricing Aspects of Financial TransactionsPart 1


In Part 1 of a 2-part series, the authors discuss their take on the final OECD guidance on the transfer pricing aspects of financial transactions (Chapter X) thatwas issued on Feb. 11, 2020.
To read more go here Subscription Required

Posted on

Insight: Should Multinational Enterprises Fear the Recent Successes of the J5?

  • By Andrew Sackey

The author discusses a new collaborative initiativebetween tax enforcement bodies in the U.K., U.S., Australia, Canada, and the Netherlands, known as the"Joint Chiefs of Global Tax Enforcement" (J5).

To read more go here Subscription Required

Posted on

Mnuchin Says Congress Key Hurdle to Europes Digital Tax Demands 

  • By Saleha Mohsin and William Horobin

European finance chiefs arrived at a meeting of their global peers in Riyadh demanding the urgent creation of a new global tax system for the 21st century thatwould capture the profits of tech multinationals. U.S. Treasury Secretary Steven Mnuchin responded: it's not that simple.
To read more go here Subscription Required

Posted on

House Bill Could Force Detailed Tax Reports From Multinationals 

  • By Nicola M. White

Large multinational companieswould have to disclose country-by-country details of profits, taxes, employees, and tangible assets of their overseas operations under a bill introduced by Rep. Cindy Axne on Thursday.while the OECD already has a global framework in place for country-by-country reporting, it does not require them to be made publicly available.
To read more go here Subscription Required

Posted on

IRS to Stick to Proposed Tax Rate for Foreign Income Tax Opt-Out

  • By Colin Wilhelm

The IRSwill stickwith an 18.9% offshore tax rate as the threshold for multinational companies looking to opt-out of a tax on a new category of foreign income, an agency official said.

To read more go here Subscription Required

Posted on

Spain to Tax Big Tech

  • By Maitane Sardon

Spain said itwill impose a digital-services tax on major tech firms such as Alphabet and Facebook, as part of its goal to tackle the country's deficit and encourage companies to pay taxeswhere they generate benefits.

To read more go here Subscription Required

Posted on

Beijings Soft Power Push on Global Tax

  • By Rochelle Toplensky

China's trillion-dollar Belt and Road initiative to build infrastructure connecting Asia, Africa, and Europe has generated plenty of headlines, but its tax arm remains little known. Companies and policymakers alike need to pay closer attention. The project could end up affecting how multinationals pay tax and resolve disputes around the globe.

To read more go here Subscription Required

Posted on

Heres How the EU Could Tax Carbon Around the World

  • By Ewa Krukowska

The author discusses the European Union's plan for reducing carbon emissions from its factories and to prevent the rest of theworld fromwiping out those reductions and killing lots of European jobs at the same time.

To read more go here Subscription Required

Posted on

Turkey Faces Tax Blacklist If No Changes to Policy, Austria Says

  • By Boris Groendahl

Turkey has until the end of the year to complywith European Union demands on tax transparency, or else risk being added to a list of countries that could face financial sanctions, according to Austrian Finance Minister Gernot Bluemel. The rules include bilateral agreements to automatically exchange bank informationwith EU members,which include Cyprus.

To read more go here Subscription Required

Posted on

Insight: OECD's Preliminary Economic Analysis Highlights Need for Pillar Two Information and Engagement 

  • By Jefferson Vanderwolk

In light of the OECD's preliminary analysis, the author discusses the issue of double taxation under the proposed Pillar Two rules.

To read more go here Subscription Required

Posted on

European Union Proposes to Amend Council Directives for Administrative Cooperation in Tax Matters


The EU proposal includes measures thatwould expand existing information exchange and create new information disclosure rules.

To read more go here Subscription Required

Posted on

Insight: Pillar One of the OECD BEPS Action 1-The Ambitious Time-Bound Goals

  • By Alexandre Mercier

The OECD intends to reach a consensus on the Inclusive Framework by the end of 2020. In light of that goal, the author examines the Framework's concepts, disparate interpretations, andwhat needs to be done to achieve a consensus.

To read more go here Subscription Required

Posted on

Practitioners Fear BEPS 2.0 Agreement May Not Be Good Enough

  • By Ryan Finley

Even if international consensus is reached on a minimum tax regime and a new approach to allocating taxing rights, practitioners are concerned that dissatisfied countrieswill retain their unilateral measures or push for further reforms.

To read more go here Subscription Required

Posted on

IRS Not Yet Convinced of Lower-Tier DRD Applicability

  • By Andrew Velarde

If taxpayerswish to convince theIRSthat upcoming guidance should apply thedividends received deduction(DRD) to lower-tier dividends from specified foreign corporations (SFCs) to a controlled foreign corporation, they may havework to do.

To read more go here Subscription Required

Posted on

Economic Analysis: OECD BEPS Economic Impact Assessments Made Simple

  • By Martin A. Sullivan

Martin A. Sullivan ponders the possibilities of further base-erosion-and-profit-shifting-related estimates by the OECD and by others.

To read more go here Subscription Required

Posted on

Norway Proposes Intragroup Interest and Royalty Withholding Tax

  • By Ryan Finley

As part of its effort to prevent profit shifting, Norway'sMinistry of Financehas released a proposal for a newwithholding tax on interest and royalties paid to related parties resident in low-tax countries.

To read more go here Subscription Required

Posted on

South African Treasury Proposes OECD-Endorsed Interest Cap

  • By Ryan Finley

Following the approach recommended by the OECD and the African Tax Administration Forum, South Africa's National Treasury has proposed restricting deductible net interest as a percentage of earnings before interest, taxes, depreciation, and amortization.

To read more go here Subscription Required

Posted on

Vodafone, Tesco Lose Hungarian Turnover Tax Cases at CJEU

  • By Amanda Athanasiou

The Grand Chamber of the EU's highest court has found that Hungarian turnover-based taxes on telecom and retail operations don't violate the freedom of establishment, even though the tax burden falls heavily on foreign-parented operations.

To read more go here Subscription Required

Posted on

Hungarian Advertising Tax Penalty Regime Violates EU Law

  • By Kiarra M. Strocko

Hungary's imposition of cascading fines related to Google Ireland's failure to submit a tax declaration for its advertising services constitutes a restriction on the freedom to provide services, according to the EU's highest court.

To read more go here Subscription Required

Posted on

Need for the U.K.s DPT Under Ongoing Review, Officials Say

  • By Ryan Finley

Although the United Kingdom's diverted profits tax (DPT) has become a powerful transfer pricing enforcement tool, itwasn't intended to be permanent and its future necessity remains under review, according toHM Revenue & Customsofficials.

To read more go here Subscription Required

Posted on

Unnecessarily Complex OECD Proposals Encourage Tax Planning

  • By Kiarra M. Strocko

TheOECD's proposals on the reallocation of taxing rights are "unnecessarily complex" and could lead to the establishment of tax avoidance practices and international conflicts, according to a study by European research institutes.

To read more go here Subscription Required

Posted on

U.K. to Mull Digital Taxation as Part of U.S. Trade Policy

  • By Stephanie Soong Johnston

The United Kingdomwill take public comments about digital taxation into account as it shapes its trade policywith the United States, according to its negotiating mandate for a U.K.-U.S. free trade agreement (FTA).

To read more go here Subscription Required

Posted on

Corp. Tax Rates In Political Sights Amid Presidential Race

  • By Alex M. Parker

Some of theworld's largest corporations are finding their financial statements under unwelcome scrutiny as activists ÔøΩ and candidates in the 2020 presidential race ÔøΩ claim they reveal low effective tax rates and loopholes in the system.

Posted on

OECD Looks To Cloud Computing To Broaden Digital Tax Scheme

  • By Alex M. Parker

The Organization for Economic Cooperation and Development appears to be broadening the scope of its proposed new global taxing regime to include more digital and online activities such as cloud computing and other business-to-business services.

Posted on

OECD Tax Certainty Pilot Closed To New Biz, IRS Official Says

  • By Natalie Olivio

The Organization for Economic Cooperation and Development's program for tax administrations and multinational corporations to openly discuss transfer pricing issues isn't currently taking on any new companies, an Internal Revenue Service official said Thursday.

Posted on

Businesses anxious over Greek digital platform law

  • By Mattias Cruz Cano

Companies in Greece are concerned over the vague details of tax legislation that requires online platforms to provide information on sellers. The new law comeswith severe measures for non-compliance.

Posted on

South Africa looks to broaden its corporate tax base

  • By Mattias Cruz Cano

South Africa's Finance Minister Tito Mboweni has announced that the countrywill aim to increase its corporate income tax base and signalled a future rate reduction. The VAT rate remains unchanged amid minor changes on indirect taxes.

Posted on

Multinationals Taxed at Higher Rate Than Congress Expected

  • By Alexis Gravely

Lawmakerswho supported the Tax Cuts and Jobs Act's global intangible low-taxed income regime didn't realize that some multinational corporationswould end up paying much more in tax thanwas anticipated, according to a former senior tax counsel.

To read more go here Subscription Required

Posted on

Economic Analysis: Segmenting Business Boosts OECD Pillar 1 'Amount A' Reallocations

  • By Martin A. Sullivan

In economic analysis, Martin A. Sullivan examines how any OECD requirement that large multinational corporations calculate their pillar 1 amount A profit reallocations from source countries to market countries could result in significant tax increases.

To read more go here Subscription Required

Posted on

The OECD Project That Shall Not Be Named

  • By Mindy Herzfeld

The OECD's base erosion and profit-shifting project had a catchy name: BEPS. But in a recent statement from the OECD/G-20 inclusive framework on BEPS, the organization refers to its latest undertaking as the "Two-Pillar Approach to Address the Tax Challenges Arising From the Digitalisation of the Economy." The inability to come upwith a succinct title for a project that in reality is awholesale rewrite of international tax rules reflects a deeper problem: The project means different things to its participants, its opponents, and even its advocates.

To read more go here Subscription Required

Posted on

Belgian Government Wants Exemptions to GLOBE Minimum Tax

  • By Elodie Lamer

The Belgian tax administration says patent boxes should be exempted from the OECD's proposed global anti-base-erosion (GLOBE) minimum tax.

To read more go here Subscription Required

Posted on

G-20 Ministers Back New Roadmap for OECD Global Tax Deal

  • By Stephanie Soong Johnston

G-20 finance ministers haveendorsed an updated roadmap to guide OECD-level negotiations on a global tax overhaul deal by the end of 2020, underscoring the importance of agreement on elements of that solution by July.

To read more go here Subscription Required

Posted on

House Bill Seeks To Force Multinationals To Disclose Tax Havens

  • By Joseph Boris

Legislation recently introduced in the U.S. House of Representativeswould force large multinational companies to provide country-by-country financial reports that the bill's Democratic sponsors saywould reveal the possible use of offshore tax havens.

Posted on

KPMG Study Casts Doubt on Key OECD Global Tax Deal Design Issue

  • By Ryan Finley and Stephanie Soong Johnston

Anew economic analysis fromKPMGthrows into question the need for differentiation in amount B of theOECD's so-called unified approach for modernizing corporate tax rules for the digital age.

To read more go here Subscription Required

Posted on

Economic Analysis: OECD Pillar 1 'Amount A' Shakes Up Worldwide Profit

  • By Martin A. Sullivan

In economic analysis, Martin A. Sullivan uses details from an OECD proposal and real but imperfect data to mimic how the OECD may begin to tax the digital economy.

To read more go here Subscription Required

Posted on

Zuckerberg to say Facebook will accept more taxes, new rules

  • By Marty Johnson

Facebook founder and CEO Mark Zuckerberg is expected to deliver remarks on Saturday in Germany expressing his company's acceptance of having to pay more taxes under global tax reforms."I understand that there's frustration about how tech companies are taxed in Europe.we alsowant tax reform and I'm glad the OECD [Organization for Economic Cooperation and Development] is looking at this," excerpts of Zuckerberg's speech read, Reuters reports.

Posted on

Dems' Bill Would Nix Treasury's High-Tax Exception To TCJA

  • By Natalie Olivio

A bill proposed by two Democratic senatorswould reverse a recent U.S. Treasury Department proposed regulation thatwould exempt corporate income already taxed at high rates from the 2017 tax overhaul's global minimum tax.

Back to top