Int'l Tax News

Taxpayers and advisors say Brazil's proposal to overhaul the multiple indirect tax regimes and rates into a single system have a good chance of succeeding because of the need for simpler tax rules. But progresswill be slow.

By Stephanie Soong Johnsto

The Tax Cuts and Jobs Act's global intangible low-taxed income provision must be treated as a compliant minimum tax in any OECD proposal to adapt international tax rules to the digital age, CEOs said.

By Tax Analyst

The Business Roundtable, a nonprofit U.S. organization, urged the Organization for Economic Cooperation and Development to continue to oppose double taxation, promote effective dispute resolution, and minimize changes to profit allocation and rules on the right to tax,while they are considered as international tax rule changes.

By Ryan Finley

Although Ireland does not oppose the OECD's efforts to modernize the international tax system, the government believes that the existing transfer pricing framework must be preserved, according to Irish Minister for Finance Paschal Donohoe.

By Tax Analyst

In a September 17 overview of a General Court of the European Union hearing of a case regarding the European Commission's 2016 decision finding Ireland granted illegal state aid to Apple Sales International and Apple Operations Europe, Ireland's Department of Finance noted that they are contesting the decision on the basis that they have not given favorable tax treatment or granted state aid to Apple or its subsidiaries.

By Tax Analyst

The Dutch government introduced its 2020 tax plan on September 17, outlining implementation of a national climate agreement, income tax and VAT cuts, and a corporation tax rate increase.

By Teri Sprackland

If an international agreement on digital taxation is not reached next year, the next European Commissionwill propose a Europeanweb tax, the incoming EU tax commissioner said.

By Andrew Goodall

Reducing U.K. corporation tax to 17 percent in 2020 is a stupid policy that has had no impact on investment decisions, according to Susan Kramer, Liberal Democrat Treasury spokeswoman in the House of Lords.

By Isabel Gottlieb

Theworld's biggest polluting countries aren't doing enough to tax carbon consumption and encourage cleaner energy, an OECD report found.

By Linda Thompson

Dutch opposition lawmakers are pressing the government to abandon plans to cut the headline corporate tax rate by almost four percentage points in 2021.

By Aoifewhite and Stephanie Bodoni

Apple Inc. and Ireland's court room clashwith the European Commission finally lived up to its billing as theworld's biggest tax case.

By Siri Bulusu

Sen. Amy Klobuchar has asked Treasury if it is taking steps to block companies from offshoring jobs because of tax incentives.

Taxing capital holdings boosts rewards for investingwell.

Apple 's ÔøΩ13 billion ($14.4 billion) tax fightwith Europe is grinding through the courts. It could end up generating unwelcome headlinesÔøΩfor Apple and Brussels alike.whatwas a story about the European Union hittingwhat it sees as an undertaxed technology giant has turned into a tussle for billions in tax revenue between Brussels andwashington. The shift is awkward for European officials,who are seeking to avoid a tradewarwith President Trump.

Italian taxpayers evaluate the benefits of a new option in the patent box regime allowing companies to make autonomous calculations of tax benefits.

The Indian government on Friday announced a slew of concessions aimed at boosting the economy thatwill reduce most corporate taxes for local companies to about 25% from 30%. Finance Minister Nirmala Sitharaman said the lower tax rateswill retroactively apply from April 1, the beginning of India's fiscal year.

By Joe Kirwin

European Union finance ministers meeting in Helskini agreed to consider adopting a carbon border tax on imports coming from countries that didn't commit to the Paris Agreement.

By Hamza Ali

A global minimum tax thatwill ensure tech giants "pay their fair share" is on the horizon, Germany's finance minister Olaf Scholz said in at meeting in Finland.

By Jessica Shankleman

The opposition Labour Partywould seek to expand a tax on financial transactions if it is elected to government, according to the party's Treasury spokesman John McDonnell.

By Stephanie Bodoni

Google got a boost in a tax case at the European Union's top court that's made the search-engine giant an unlikely ally of EU antitrust chief Margrethe Vestager in a clashwith Hungary.

By Andrea Navarro

Mexico's tax collectors are taking a big step in their bid to get a piece of the booming digital economy pie.

By Joe Stanley-Smith

The OECDwill for the first time rank countries on how effectively they negotiate to resolve tax disputes, a top tax official from the organization said.

By Siri Bulusu and Hamza Ali

Up to 24 governments could be in the firing line of punishing U.S. trade policies if they go aheadwith their individual digital tax plans, a senior U.S. Treasury officialwarned.

By Isabel Gottlieb

Fresh details on the OECD's digital tax projectwill be out early October, but a full analysis of its impact on countries' revenueswon't be ready this year, the group's tax chief said.

By Hamza Ali

The U.S. Treasury has urged the OECD not to narrowly focus on industries like social media in its recommendations to reform theway countries tax the digital economy.

By Patrick McGee and Javier Espinoza

The iPhone's appeal to its ÔøΩ13bn fine is heard sameweek as its latest product launch.

By Thomas Horst

In this article, the author estimates the actual revenue effects of four international provisions of the Tax Cuts and Jobs Act and compares his estimates to the projections made by the Joint Committee on Taxation staff in December 2017.

By Barry Larking

Barry Larking compares the different group taxation regimes in the European Union, focusing on the Netherlands' current group taxation regime,which it is considering abolishing.

By Rogerio Abdala Bittencourt Jr. and Antonio José Ferreira Levenhagen

Rogerio Abdala Bittencourt Jr. and Antonio José Ferreira Levenhagen discuss how Brazil can align its tax ruleswith international standards in the areas of fiscal and financial secrecy, tax evasion, avoidance, and aggressive tax planning in preparation for accession to the OECD.

By Annagabriella Colon

Four months after requesting comments about individual and corporate tax morale, the OECD has finalized a report outlining factors that influence tax compliance, stressing the importance of such information for developing countries.

By Ryan Finley

The distinction between residual and routine profit that forms an integral part of some OECD proposals for new profit allocation rules is fundamentally flawed, according to a report by the BEPS Monitoring Group.

By Stephanie Soong Johnston

A conservatively high threshold for excess profits in an OECD approach to tax the digital economy could be an appropriate departure from the arm's-length principle and nexus standards, a top U.S. Treasury official said.

By Reuven S. Avi-Yonah and Kimberly Clausing

Reuven S. Avi-Yonah and Kimberly Clausing make a case for the United States to adopt a sales-based formulary apportionment solution for all large enterprises,whichwould provide a more stable outcome than OECD proposals for taxing the digital economy.

By Stephanie Soong Johnston

Countries are less keen on introducing unilateral measures now that an OECD-led multilateral approach to adapt the international tax rules to the digital age is imminent, according to the OECD's top official.

By Tax Analyst

In a September 9 letter, Sens. Amy Klobuchar, D-Minn., Chris Van Hollen, D-Md., and Tammy Duckworth, D-Ill., alongwith Rep. Peter A. DeFazio, D-Ore., asked Treasury Secretary Steven Mnuchin and IRS Commissioner Charles Rettigwhat steps they are taking to "mitigate the incentives for offshoring created by the 2017 tax law."

The Dutch government said Tuesday it plans to reform a business tax rule that allowswealthy multinationals to reduce the amount of tax they pay on their profits. The government said the plan,which has to be passed by parliament,will generate 265 million euros ($292 million) per year in new income. The announcement follows public outrage at revelations this year that some multinationals paid little or no tax on their profits.​

Tech giant Google said Thursday it has paid over one billion dollars to French authorities to settle a years-long dispute over allegations of tax fraud. A Paris court approved a penalty of 500 million euros ($551 million) from the digital giant over charges of tax evasion, and Google said it paid a further 465 million euros ($513 million) in "additional taxes."

By Victoria Perry, Alexander Klemm, and Shafik Hebous

Efficiency-improving tax reforms in German are possible, ideally to address the domestic tax competition and complexities arising from having both a federal and a municipal corporate income tax, and in any event through technical reforms to address certain inconsistencies that have arisen in the interaction of anti-avoidance provisionswith other tax laws.

By Steven C.wrappe and Marenglen Marku

In this article, the authors detail how tariff costs affect transfer pricing analyses, and they examine the best options available to companies in the absence of meaningful tax guidance.

By H. David Rosenbloom and Fadi Shaheen

In this article, the authors examine how corporate tax changes implemented by the Tax Cuts and Jobs Act interactwith U.S. tax treaties.

By Teri Sprackland

Abandoning permanent establishment as a basis for taxation could reduce France's tax base, a governmentwatchdog haswarned.

By Carrie Brandon Elliot

Carrie Elliot describes how a taxpayer's decision to capitalize property into inventory could increase QBAI and decrease GILTI inclusions.

By Mindy Herzfeld

In the first article in a series reviewing provisions that could be included in future tax legislation, Mindy Herzfeld examines proposals from the Obama administration, the 2014 Camp bill, and the 2016 Betterway Blueprint.

By Martin A. Sullivan

In economic analysis, Martin A. Sullivan offers a few generalizations about the tax treatment of global intangible low-taxed income, providing calculations on the effect of changes in profit movement on taxes.

Bywilliam Hoke

Legislation thatwould require foreign companies that provide digital services to Mexicans to pay VATwas published in the parliamentary gazette September 5.

Bywei Zhuang

Wei Zhuang discusses the major regulations to implement BEPS in China and analyzes the impact on tax administration and tax compliance. She also provides an outlook on China's tax administration in combating BEPS.

By Stephanie Soong Johnston

Although countries have not decreased their corporate income tax rates in 2019 as drastically as they did in 2018, those rates continue to converge as countrieswith the highest rates have introduced the most significant cuts.

By Colinwilhelm

Negotiations between the Trump administration and France are continuing over that country's planned tax on digital services, Treasury Secretary Steven Mnuchin said.

By Hamza Ali

A global minimum tax being considered by the OECD could make rules on tax-avoiding hybrid mismatch structures redundant, an official from the organization said.