Int'l Tax News

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.

By Joe Kirwin

Paolo Gentiloni has hiswork cut out for him as the EU's next tax czar, succeeding France's Pierre Moscovici.

By Hamza Ali and Isabel Gottlieb

A global plan to rewrite how the digital economy is taxed could create new conflicts between countries hoping for a bigger bite of multinationals' profits.

By Joshwingrove and Caitlinwebber

Treasury Secretary Steven Mnuchin told reporters that trade talkswith France are goingwell and that the administration is reaching out to industry groups on digital tax proposals over the comingweeks.

By Jan Stojaspal

Poland has delayed plans to roll out its own digital tax on global tech companies.

By Siraphob Thanthong-Knight

Thailand's new stimulus package aimed at attracting companies and manufacturers to the countrywill be submitted for Cabinet's approval on Sept. 10, Kobsak Pootrakool, a deputy secretary-general in the Thai premier's office, said after an economic ministers' meeting in Bangkok.

The United States is meetingwith technology and other companies as it considers its options following a rowwith Paris over France's tax on big internet firms, the U.S. Treasury secretary said on Monday. Steven Mnuchin told reporters at thewhite House that effortswere ongoing after the two sides agreed at the G7 summit to seek an agreement in the next 90 days,with digital companies meetingwith U.S. Treasury officials thisweek and multinational firms coming nextweek.

Mexico is in talks to extend a sales tax to foreign online businesses so that they pay their fair share to Latin America's second biggest economy, the government said on Monday, in a move that could affect companies like Amazon.com Inc, Uber Technologies Inc and Airbnb Inc.

The move from principle-based approaches to mechanical-based approaches could expose multinationals to permanent instances of over-taxation or double taxation under BEPS Action 4 across jurisdictions.

Ireland has released a responses document on an ongoing consultation on an update to the country's transfer pricing rules. In February 2019, a public consultationwas launched to gather the views of stakeholders regarding a proposed update of Ireland's transfer pricing rules. The update is intended to respond to recommendations from the Coffey review and is also intended to incorporate the 2017 OECD Transfer Pricing Guidelines into Irish legislation.

The pace of tax reform has slowed across most leading economies, a new report from the OECD says, calling for bolder tax reforms to address future challenges. Tax Policy Reforms 2019 describes the latest tax reforms across all OECD countries, aswell as in Argentina, Indonesia, and South Africa. The report identifies major tax policy trends and highlights that fewer countries have introduced comprehensive tax reform packages in 2019 comparedwith previous years.