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The EU's Coordinated Approach to Transfer Pricing Controls


In this article, the author examines the coordinated transfer pricing control framework developed by the EU Joint Transfer Pricing Forum. He considers how it can resolve some of the problems caused by the transfer pricing framework that resulted from the OECD's base erosion and profit-shifting project.

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Treasury to Delay 'Tested Losses' Rules Under Global Minimum Tax


Treasury is delayingwork on outstanding issues related to controlled foreign corporations' losses under an international provision of the 2017 tax overhaul. "The rules relating to tested loss adjustments in stock basiswill not be finalized as part of the GILTI package that is expected this summer," saidwade Sutton, senior counsel in the Treasury Department's Office of International Tax Counsel.

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Nordic Countries Likely to Reject Proposed EU Digital Tax


The year-long European Union effort to approve a temporary digital advertising tax thatwould hit companies such as Google Inc. and Facebook Inc.will likely face a pivotal defeat. Nordic countries joined by Ireland and Malta plan to oppose the EU's proposed tax on the turnover of large Internet companieswhen the EU finance ministers meet March 12.

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India Planning 300% Tax Incentive to Boost Electric Car Sector


India's government is planning a tax-incentive bonanza to boost the country's nascent electric vehicle sector thatwould include a 300 percent tax break for research and development.

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Ireland to Hike Carbon Taxes, Minister Says


Irelandwill soon start to increase its tax on carbon in attempt to meet its climate change goals for 2020 and beyond, the country's environment chief told business leaders in Boston March 11.

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Kudlow Says Trump's Tax Cuts Already Paying for Themselves


President Donald Trump's top economic adviser said that the administration's historic $1.5 trillion tax-cut packagewas already paying for itself amid sustained economic growth. "I thinkwe have already paid for a good chunk of it," National Economic Council Director Larry Kudlow said at an April 11 event inwashington, adding that the U.S.'s budget outlook is not "as bad as many people say." But Kudlow's claim contrastswith available government data.

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Corporate America is failing to invest


Oops.when Donald Trump swept to power two-and-a-half years ago, he promised to unleash a Made-in-America investment boom. Cue pictures of the president inworthy,widget-producing factories. Add to that corporate tax cuts in late 2017, coupledwith measures to encourage the repatriation of overseas corporate cash piles, supposedly to boost capital expenditure. Events, however, have not played out quite as expected.

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Warren Pushes New Corporate Tax on Profits Above $100 Million


Democratic presidential candidate Elizabethwarren rolled out a proposal April 11 to levy a 7 percent tax on corporate profits above $100 million,which if enactedwould raise an estimated $1 trillion from the country'swealthiest businesses.

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France Takes a Step Closer to Making 3 Percent Digital Tax Law


France is moving toward passage of the first digital tax bill that tech giantswould pay this year,with the National Assembly approving the measure late April 9 and sending it to the Senate for consideration in May.

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Barrick Says Zambia Royalty Change Is Hitting Copper-Mine Profit


Barrick Gold Corp.'s Zambian copper mine has been "severely impacted" by recent increases in mining royalties, according to the head of the company's local unit. Zambia introduced new mining royalties from January as part of efforts to ensure the country gets more benefit from its natural resources.

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Microsoft's Green New Deal: Tech Giant Joins Exxon-Backed Group


Microsoft Corp. is joining a climate advocacy group backed by big energy corporations and high-profile Republicans, an effort by the software giant to find middle ground on environmental issues that have polarized U.S. politics.

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India Proposes Changing Tax Rules to Catch Digital Companies


Indiawants to broaden its tax calculation rules to include the number of individuals using a foreign company's services, advancing its quest to boost taxation of large digital companies. In an April 18 report, the tax office proposed including usersÔøΩalongside established metrics like employees and assetsÔøΩwhen determiningwhat share of a multinational's profits are attributable to their Indian operations and can therefore be claimed as tax.

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EU Passes Law to Restrict Tax-Evading Letterbox Companies


Countries in the European Union can restrict cross-border mergers if they suspect the move is an effort to set up letterbox companies to evade taxes under legislation passed by the European Parliament. The new cross-border merger legislation, approved April 18, establishes an "anti-abuse" clause thatwould halt abusive structures. The goal is to regulate the EU's freedom-of-establishment principle,which underpins the EU single market.

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Swedish Moderates Warn Tax Hike May Lead to Electricity Shortage


Swedish Moderate Party Leader Ulf Kristersson says that the government's plan to raise carbon and energy taxes for combined heat and power units later this year "risks creating really acute problems for Sweden's security of power supply," Dagens Industri reports.

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Jersey to Amend Economic Substance Law


Jersey Minister for External RelationsIan Gorston April 11 registered a draft law thatwould amend the recently enacted Taxation (Companies ÔøΩ Economic Substance) (Jersey) Law 2019with retroactive effect from January 1.

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Taxes Revisited as Alternative to Potential Backlash


During discussions about conflicts between U.S. income tax treaties and the base erosion and antiabuse tax, Christopher Bowers explained how President Trump could use two code sections to respond to retaliatory taxes imposed by other countries.

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German Government Submits SME-Focused R&D Allowance Law


The German government has submitted a draft law thatwould establish a 25 percent research and development allowance open to all taxpayers in an effort to encourage innovationwithout favoring large and profitable enterprises.

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Minimum Taxation May Curb Developing Countries' Incentive Use


One idea emerging from OECD-levelwork on a long-term solution to tax the digital economy is that minimum taxation may relieve the pressure on developing countries to offer incentives, a top OECD official said.

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Taxing Online Advertising in Germany: Royalties or Payment for Services?


In this article, the author discusses Germany's approach to taxing online advertising services, reviewing the arguments for treating payments as royalties and advocating instead for treating online advertising as a provision of services. She also offers insight and advice for both German customers and foreign service providers.

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Memo Supports IRS's Authority to Address GILTI Expense Allocation

  • By Tax Analysts

An individual has submitted a memorandum stating that Treasury and the IRS have ample authority to eliminate or significantly limit the allocation of U.S. shareholder expense to income in the global intangible low-taxed income, foreign tax credit basket.

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Senator Seeks Exception From BEAT for Servicing Agreements

  • By Tax Analysts

Sen. Thom Tillis, R-N.C., has requested an exception to the base erosion and antiabuse tax under section 59A for payments made by U.S. manufacturers to their foreign affiliates that are service centers because that legislationwas never intended to capture manufacturers providing services to unrelated customers outside the United States andwould defeat the purposes of the BEAT.

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World Business Organization Issues Digital Economy Statement

  • By Tax Analysts

The International Chamber of Commerce has proposed a new framework of internationally established tax principles, such as making tax proposals for the digital economy profits-based, applying the same principles of taxation to all forms of business, and eliminating double taxation in tax rules and systems.

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India Denies Report That France Waived Tax Claim to Sell Jets


India's Defense Ministry denied a press report that the French governmentwaived ÔøΩ143.7 million in taxes owed by Reliance Communications Ltd. because the Indian government agreed to buy 36 jets from France's biggest defense manufacturer.

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Revamped Financial Transactions Tax Gains Momentum in EU


Ten EU member states negotiating a financial transactions tax are said to be close to a legal text, but political issues remain.

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U.S. Tax Review (2)


In this article, the authors discuss the newly proposed foreign-derived intangible income regulations.

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FDII Transportation Rules Reflect Administrability Concerns


Bright-line rules from the IRS regarding transportation services and sales under the proposed regs on foreign-derived intangible income are indicative of an agency concernedwith administrability.

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LB&I Campaigns Target Transfer Pricing, Reporting Requirements


The IRS's Large Business and International Division has announced three new compliance campaigns that focus on transfer pricing for captive service providers and tax and information reporting requirements concerning offshore activities.

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France to ask EU partners to adopt its cryptocurrency regulation

  • By Reuters

Francewill push for the European Union to adopt a regulatory framework on cryptocurrencies similar to the one it brought in lastweek at a national level, becoming the first major country to do so, French Finance Minister Bruno Le Maire said on Monday.

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EU Threatens to Tax $20 Billion of US Goods Over Boeing Aid

  • By The Associated Press

The European Union has drawn up a list of $20 billionworth of U.S. products it could tax in an escalating feud over plane industry subsidies, the EU's executive commission saidwednesday.

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Expect 'Looser' OECD Tax Avoidance Project Plan: Official


A deal among countries at the OECD on international tax avoidancewill likely be a "looser" plan leaving many of the details for individual countries to implement, an officialwith the U.S. Department of the Treasury said Tuesday.

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Singapore's consistent, agile support for innovation and IP in a digital age


Singapore has been agile in refining its support for companies investing in the acquisition, development, enhancement and exploitation of intellectual property rights,which is the key to innovation in the digitalized economy of the future.

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Austria proposes new, permanent digital tax


Austria has proposed a new digital services tax (DST), motivated by a desire to level the playing field for domestic media companies,which it says itwould not repeal even if the OECD reaches consensus on digital tax measures.

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Polish Finance Ministry Proposes Simplified APA Procedure


Poland's Ministry of Finance has issued a draft bill on a simplified advance pricing agreement process thatwouldwaive deductibility restrictions on intragroup expenses.

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Netherlands Launches Major Review of Tax System


The Dutch governmentwill begin a broad reassessment of its tax system thatwill examine the current tax mix and its distributive effects, taxation of income from digital sources, and the future of corporate taxation.

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South Korea to cut stock transaction tax from June 3 - media reports

  • By Reuters

South Korea's finance minister said the planned tax cut for stock transactionswill begin on June 3, according to local media reports on Sunday.

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U.S. Consumer Sentiment Drops as Tax-Cut Boost Fades


Consumers' outlook on the U.S. economyworsened in April, as a survey suggested the impact of tax cuts has now run its course for American households. The University of Michigan said Friday its preliminary index of consumer sentimentwas 96.9 this month, down from March's final reading of 98.4. That undershot economists' expectations for a preliminary reading of 98.0.

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EU Wants Members to Drop Veto Over Possible Carbon Tax

  • By The Associated Press

The European Union's executive branch is proposing that individual member countries drop their right to veto decisions on energy taxes, a move that could facilitate the introduction of a carbon tax across thewhole bloc.

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Report finds twice as many companies will pay zero in taxes this year


A new report, citing data from a left-leaning think tank, reveals that at least 60 companies avoided paying taxes this year as a result of the new tax law ÔøΩ a total that is about twice as many as previous years.

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Fixing our 'America Last' tax policy


Tax Cuts and Jobs Act is a regressive response to the challenges posed by today's global economy. Not only do the vast majority of the tax benefits from the legislation accrue to those at the top of the income distribution, but the legislationweakens the health security of ordinary Americans. Reduced spending on health insurance subsidies for poor Americanswill increase the number of uninsured Americans and generate more expensive premiums for those that remain insured.

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EU Commission Hopeful Backs Continental Minimum Corp. Tax


A top candidate for the European Commission presidency said Thursday he supports a Europewide minimum corporate tax because European Union countries are no longer powerful enough to extract a fair amount of revenue from the largest companies on their own.

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Elizabeth Warren Proposes New Corporate Tax


Democratic presidential candidate Elizabethwarren is proposing a new 7% tax on the largest, most profitable U.S. companies, a move thatwould increase corporate tax collections by about 30% over the next decade.

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Germany's Scholz Wants Progress on Global Corporate Taxation

  • By Reuters

German Finance Minister Olaf Scholz told Reuters in an interview onwednesday hewould urge financial leaders during meetings inwashington later thisweek to aim for a minimum level of corporate taxation globally.

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Why more tax reform is inevitable


The 2017 tax law looks appealing to many citizens because it handed out a lot of money thatwould otherwise have gone to the Treasury. However, the oversized budget deficits, caused in part by the unavoidable aging of our population,will force lawmakers to revisit that tax law. The American people should be prepared for another very different dose of tax reform.

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Investors want a global standard for MNE tax disclosures


Investors are using multinational companies' tax disclosures, such as country-by-country reports, to inform their investment decisions - andwant consistent disclosure formats to make comparisons easier.

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Taxing the Digital Economy Post BEPS ... Seriously


For years the advent of the digital economy has left countries stumped in their attempt to tax income earned by foreign firmswithout physical presencewithin their jurisdiction. International organizations and their member countries have failed in their attempts to tweak the rules of the international tax regime and address these challenges presented by the digital economy. This article argues that such conservative approach could notwork, and fundamental reform is inevitable.

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Austria Announces Five Percent Digital Tax


The Austrian Government announced on April 3, 2019, a package of tax measures aimed at the digital economy, including a five percent tax on revenue derived from the sale of digital advertising services and the removal of the low-value VAT exemption threshold.

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Australia Issues Ruling On Hybrid Mismatch Rules


The Australian Taxation Office has opened a consultation on a draft Law Companion Ruling on the targeted integrity rule thatwill apply under the new hybrid mismatch regime.

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EU Justice Commissioner Addresses Digital Taxation at Brookings Institute

  • By Tax Analysts

Vera Jourová, European Commissioner for Justice, Consumers, and Gender Equality, spoke about digitalization, data protection legislation, and challenges that the United States and European Union face regarding online data control in an April 11 speech at the Brookings Institute.

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Trade Misinvoicing Creates Trillion-Dollar Value Gap, GFI Says


Deliberate misstatements on trade invoices have created a trillion-dollar gap in the actual value of goods, leading to about $200 billion in annual tax revenue losses, according to estimates by Global Financial Integrity (GFI).

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Latin American Tax Challenges Sway Favored Digital Solution


Latin American countries' preferred proposal for addressing the tax challenges of the digital economy is driven by an eroding tax base, according to a tax specialistwith the Inter-American Development Bank (IADB).

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