Int'l Tax News

During awebcast on June 11, the OECD provided a technical update on itswork to develop new, modernized international tax rules for the digitalized economy. Under a mandate from countries that have agreed to implement the BEPS minimum standards – the BEPS Inclusive Framework – the OECD is developing new digital tax rules thatwould be presented for adoption internationally at the end of 2020. At its January 23-24, 2019, meeting, the BEPS Inclusive Framework agreed that the OECD'swork should focus on two central pillars.

Brazil made a formal application to join the OECD in 2017, but the process is still miredwith political uncertainty. Base Firma's Davi Stantana de Jesus outlines how the economy can expedite its application by reforming its transfer pricing framework.

The 2017 tax overhaul "set the stage" for U.S. participation in the OECD'swork to adapt global tax rules to the digitalization of the economy said Brian Jenn, Treasury's deputy international tax counsel, said at the U.S. Council for International Business/OECD International Tax Conference inwashington.

Global negotiations on taxing the digital economy should focus on "reallocating out of above-normal profits," according to Lafayette "Chip" G. Harter, deputy assistant secretary of international tax affairs at Treasury.

Establishing a global minimum tax for multinationals' foreign entities at the OECD level could become tricky as countries try to define that rate, a Treasury official said.

The OECD's plan to rewrite global tax rules to give more taxing rights to additional countries could harm investment in research and development, a former vice president forworldwide tax at Microsoftwarned.

New Zealand's government is still mulling adoption of a digital service tax like one being considered by several European Union countries, a senior tax official said.

The Senate should approve eight pending bilateral tax treaties, the American Institute of CPAswrote in a May 23 letter to the chair and ranking member of the Senate Committee on Foreign Relations.

Unilateral digital tax planswill increase trade tensions and hurt efforts to reach global consensus on how to tax the digital economy, Irish Finance Minister Paschal Donohoe said.

Alberta's new United Conservative Party government introduced a bill to repeal the oil-rich province's carbon tax, setting up a legal showdownwith Prime Minister Justin Trudeau over a cornerstone of his environmental policy.

The OECD's rewrite of global tax rules should focus on a plan that uses brand-related assets to shift more taxing rights to countrieswhere companies' consumers are, the Association of International Certified Professional Accountants said.

Decades of taxwars among theworld's richest countries are unravelling the century-old global corporate tax system, new research finds. Forty per cent of today's cross-border direct investments reported by the IMF – $18 trillion in value – are being booked in just 10 countries that offer corporate tax rates of 3 per cent or less.

Belgiumwould lose 9,400 jobs and ÔøΩ2.3 billion of GDPwith the introduction of a common corporate tax base, according to a recent study.

A new compromise proposal for a financial transaction tax (FTT) patterned after the French FTTwill be on the tablewhen the Economic and Financial Affairs Council meets June 14.

More than 100 countries have approved an OECD program ofwork for tackling the tax challenges of the digital economy, taking one step closer toward a potential internationally agreed solution by 2020.

Spain's acting government has called on the European Union to assess a potential carbon tax on power imports to protect the bloc's interests and help it to pursue its environmental targets amid growing public concern over climate change.

HM Revenue & Customs has opened a consultation on amendments to rules regarding taxation of the digital economy that aim to keep large multinationals from taking advantage of low-tax jurisdictions to stow their intellectual property.

In economic analysis, Martin A. Sullivan argues that Congress should pay for a lower effective tax rate on global intangible low-taxed income by increasing the 20 percent haircut on foreign creditable taxes, increase the haircut on foreign tax credits in 2026 instead of reducing the section 250 deduction, and reduce foreign tax creditability instead of raising the rate.

Carrie Brandon Elliot reviews how the section 163(j) proposed regulations intersectwith section 882 and impose two limits on interest expense deductions that reduce effectively connected income.

In news analysis Mindy Herzfeld looks at the turbulent relationship among tariffs, taxes, and trade and its influence on multinational business decision-making.

Complaints against the U.S. foreign-derived intangible income regime may become moot depending on the outcome of the OECD's project addressing the tax challenges of the digital economy.

Minimum taxation proposals under pillar 2 of the OECD-ledwork on taxing digitalization are problematic for Ireland, but discussions on taxing intangibles and intellectual property under pillar 1 hold promise, Ireland's finance minister said.

The OECD inclusive framework could soon sanction a roadmap for cultivating a potential global consensus on reshaping the international tax system, according to an OECD official.

Ireland must be open to considering a broader concept of how companies are taxed in the modern digitalizedworld, Finance Minister Paschal Donohoe said on Thursday, setting out his country's stall in a debate that is key to its economy.

The Mexican government said it has reached agreementwith several online ride-hailing and food delivery companies over thewithholding of VAT and corporate income tax (ISR) on their services.

Taxation of large companies in the United Kingdom is now comprehensive and "more robust than it has ever been," Glyn Fullelove said in his inaugural speech as president of the Chartered Institute of Taxation.

France's proposed 3 percent digital services taxwill not be challenged by the European Commission as state aid because it closely follows the commission's recent proposal, Finance Minister Bruno Le Maire told French legislators.