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OECD Looking to New U.S. Tax Law for Digital Tax Solutions
A senior Treasury official laid out elements of a new global tax planÔøΩcatalyzed by the 2017 U.S. tax overhaulÔøΩthat could forestall the Europe-U.S. standoff over the European digital tax proposal multinationals dread. The EU finance ministers are meeting Dec. 4 on the tax, and may vote to postpone any action until the OECD finds a digital tax solution all its members can agree on.
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France and Germany abandon ambitious plans for EU digital tax
France and Germany have abandoned EU plans to impose awide-ranging digital tax on tech companies, in favour of a narrow levy on advertising sales thatwould be likely to exclude giants likeAmazon andApple.
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Mike Ashley calls for 20% tax on online sales
Mike Ashley, the chief executive of Sports Direct, told MPs that they should impose a 20% tax on online sales in a bid to save bricks-and-mortar stores.
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Brady Issues Statement on EU Abandoning Digital Services Tax Plan
Houseways and Means Committee Chair Kevin Brady, R-Texas,welcomed the EU's abandonment of a proposal to tax digital services, stating that the "introduction of a new tax targeting cross-border digital serviceswould have singled out a key global industry dominated by American companies andwould have been a clear revenue grab."
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CJEU to Consider Italian Financial Transactions Tax
The Court of Justice of the European Union has published the reference for a case (C-565/18) onwhether EU law precludes Italy from charging a tax on financial transactions that involve the trading of derivatives.
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Mauritius Clarifies Place of Effective Management
The Mauritius Revenue Authority recently released a statement of practice (SP 17/18) clarifying the rules under section 73A of the Income Tax Act regarding the place of effective management.
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EU Divided Over Franco-German Digital Taxation Proposal
EU member states have not reached consensus on a proposal to tax the digital economy.
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Foreign Partner Sales Guidance Reaches OIRA Review
Guidance on the treatment of foreign partners' gains on a sale of a U.S. partnership is now awaiting approval of the Office of Management and Budget before publication.
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H.R. 5145 Would Repeal TCJA Tax Rates on Foreign Income
H.R. 5145, the Close Tax Loopholes That Outsource American Jobs Act, introduced by Rep. Rosa L. DeLauro, D-Conn.,would repeal the Tax Cuts and Jobs Act's reduced tax rates on foreign-derived intangible income and global intangible low-taxed income.
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ECON Committee Adopts Reports on Taxing Digital Companies
The European Parliament's Committee on Economic and Monetary Affairs has voted by awide margin to adopt its reports on proposals for EU Council directives on the corporate taxation of a significant digital presence and a digital services tax.
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G-20 Leaders Commit to Addressing Digital Taxation Conundrum
Leaders of the G-20 countries pledged to continueworking toward finding a common approach to address the tax issues of the digital economy,with a status update in 2019 and a final report by 2020.
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Digital Tax Talks Suggest Anti-U.S. Bias, Former Official Says
European efforts to tax the digital economy indicate a partiality for local interests that could violatewTO trade principles, according to a former U.S. official.
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MEPs Intent on Tougher Digital Services Tax
Despite the likelihood that the EU Councilwill reject a proposal to tax digital services on December 4, members of the European Parliament (MEPs) have voted in favor of recommendations to strengthen the proposed directive.
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Harter Has Sobering Warning if Allocation Consensus Breaks Down
On the eve of the OECD's task force meeting on the digital economy, a senior U.S. Treasury officialwarned of grim potential consequences if the international community fails to reach an agreement on questions of allocation.
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France and Germany to Propose Revamped Digital Tax, FTT
French and German finance ministerswill propose that the EU tax only advertising sales revenue, as opposed to the three revenue streamswithin the scope of the European Commission's digital services tax (DST) proposal.
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ECJ Rules French Dividend Tax Rules Breach EU Law
The European Court of Justice has ruled in favor of three Belgian companies that had challenged the legality of France's decision to refuse a refund ofwithholding tax collected on dividends paid by a resident company to a loss-making non-resident company. Between 2008 and 2011, Belgian companies Sofina, Rebelco, and Sidro received dividends as shareholders in French companies, it said.
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'Chaos' Feared If Global Digital Tax Deal Fails, Panel Says
As industries beyond tech hurtle toward a digital future, chaos could ensue unless consensus is reached on taxing a radically reshaped global economy, panelists at a forum inwashington, D.C., agreed Thursday.
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Deal Near On Int'l Digital Taxes, OECD Tells G-20
A deal may be close to being struck on a proposal for new international digital tax rules, according to a report released Friday by the Organization for Economic Cooperation and Development to the G-20. The OECD's Task Force on Digitalization is scheduled to deliver final recommendations to the G-20 on how to update tax rules to copewith the online and nonphysical economy in 2020,which once seemed a difficult task given the divergence of views among the organization's members.
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Facebook, Google, and Kering Group questioned by EU MEPs
Facebook and Google emphasised the importance of international consensus on changes to the international tax system to tax the digital economy and the scope of value creation during EU Parliament committee hearing.
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German Environment Minister Backs Contentious Carbon Pricing
Germany's environment minister says putting a price on carbon dioxide is "the right answer" to cut the country's emissions of greenhouse gases.
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US companies' massive cash hoard is finally coming down
The cash holdings of US companies fell nearly 10% in the first half of this year, signaling a turning point in the historic financial reserves they amassed in past two decades. Corporate America's cash mountain peaked at close to $2tn at the end of last year, according to rating agency Moody's. Some 70% of the money had piled up offshore, as companies hoarded their overseas profits rather than face tax charges by bringing them home and spending the money on things like acquisitions and stock buybacks.
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US dividends lag rest of the world despite tax cuts
The tax reforms that have transformed corporate America's earnings this year have not resulted in a similar step-change in dividend payments, according to new research showing that payouts by US companies are growing at a slower pace than the global average.
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EU's Moscovici Proposes to Scrap Unanimous Voting on Tax Bills
Tax legislation in the European Unionwould require a majority vote, not unanimous approval, for passage under a plan to be offered by Commissioner for Economic and Financial Affairs Pierre Moscovici. In Nov. 27 testimony before the European Parliament Tax Committee, Moscovici told the panel that the EU has "touched the limits" in legislative gridlock over tax laws because of the requirement for unanimous approval of tax legislation.
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Crown Dependencies Customs Union Boosts U.K. Brexit Plans
Isle of Man, Jersey and Guernsey have signed an agreement to keep their current customs arrangementswith the U.K. after Brexit, giving clarity to businesses based in the crown dependencies. Thiswould mean that no customs dutywill be applied to goods moving to and from the crown dependencies and U.K. after Brexit and They also agreed to impose the same external tariff on external trade.
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Financial Transactions Tax- a U.K. Perspective
The European Commission's proposal for an EUwide tax on financial transactions has generated much public and political discussion since itwas first published on September 28, 2011. This article discusses the proposal for the introduction of a financial transactions tax both in the EU and U.K. and the possibility of its enactment.
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Nordic Countries, Ireland Dash EU's Hopes for 2018 Digital Tax Deal
The chances of a digital tax on large internet companies like Facebook and Alphabet Inc.'s Google vanished Nov. 28when Ireland, Sweden, Denmark and Finland refused to agree to impose the temporary 3 percent levy.
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U.S. Companies Get Some Relief from IRS's New Foreign Tax Rules
U.S. companieswon some concessions from the Internal Revenue Service following proposed regulations thatwould soften the blow of a new foreign tax -- but the rules didn't go as far as the business community had hoped.
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ATO Guideline Targets Profitability for Inbound Distributors
The Australian Taxation Office (ATO) has issued a new draft risk assessment guideline that rates inbound distributors' transfer pricing compliance risk based on the ratio of earnings before interest and taxes (EBIT) to sales.
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New U.S. Transfer Pricing Regulations on Treasury's Radar
Tentative plans to revamp the transfer pricing ruleswith a new intangible property definitionwould add nothing new to the Tax Cuts and Jobs Act (P.L. 115-97), according to a top Treasury official.
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IBM, GE Meet With Treasury and OMB Amid BEAT Concerns
Treasury and the Office of Management and Budget continue to sit downwith concerned taxpayers as the proposed regs for the base erosion and antiabuse tax await final approval.
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G-20 Leader Unity Key to Digital Taxation Agreement, OECD Says
G-20 leaders must unite to keep political momentum going at the highest level so that countries stand a good chance of agreement on a long-term approach to taxing the digital economy, the OECD's chief said.
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The Spanish Financial Transaction Tax Will See The Light Soon: EU Context And Interview With ATTAC
Spainwill be the next European country to introduce the Financial Transaction Tax (FTT),which is estimated to raise ÔøΩ8.45 billion ($9.57 billion) in 2019, according to the Government's forecasts. The main objective of the FTT,which many refer to as the Tobin tax, is to introduce the tax system into the financial sector and to increase the tax collection of the States. In this case, however, it also responds to the need to justify the budget plan presented by Madrid in Brussels last October,where the Spanish Government proposed a deficit reduction of 0.4% for next year instead of the 0.65% suggested by the European Commission.
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Biz groups praise tax law fixes in Brady's bill
Business groups are praising the new tax package from Houseways and Means Committee Chairman Kevin Brady (R-Texas) for including technical corrections to the 2017 tax-cut law. The bill Brady released Monday includes five provisions that aim to correct areas of the 2017 tax lawwhere therewere unintended consequences. Two technical corrections in Brady's billwould address priorities of the retail industry. Another provision in Brady's billwould help businesses receive tax refunds.
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Google, Facebook Defend Tax Structures To EU Lawmakers
A Facebook tax official denied the company had sought special tax treatment in Europe and a Google executive committed to ending structures in Bermuda as European Union lawmakers sought Tuesday to probe suspected aggressive tax planningwithin the bloc. At a hearing held in Brussels, a tax executive from luxury clothing firm Kering also said the company's decision to use a Swiss structurewas "strategic" rather than tax-motivated. This is after statistics suggesting the company's employees in Switzerlandwere 115 times more productive than other staff raised eyebrows among lawmakers.
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House May Vote On Year-End Tax Bill This Week, Brady Says
The U.S. House of Representativeswill likely vote thisweek on a year-end tax package, released Monday evening by Houseways and Means Committee Chairman Kevin Brady, R-Texas, he told reporters Tuesday. The package ÔøΩwhichwould correct parts of the Tax Cuts and Jobs Act, renew expiring tax incentives, enhance tax-advantaged retirement accounts and provide temporary relief for victims of recent natural disasters ÔøΩwill likely be brought to a vote thisweek, at the discretion of House Majority Leader Kevin McCarthy, R-Calif., Brady said.
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House Lawmakers Propose Bipartisan Carbon Tax Bill
House lawmakers from both parties announced legislation Tuesday evening thatwould impose a tax of $15 per metric ton on carbon emissions starting in 2019 thatwould increase by $10 each following year. In addition to a carbon tax, the Energy Innovation and Carbon Dividend Act of 2018would also impose a tariff on imports not subject to a similar tax at home andwould rebate to the American public all the revenue raised by the bill.
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Treasury Offers Halfway Solution to Companies Vexed by Foreign Tax Rules
The Treasury Department issued long-awaited corporate tax regulations onwednesday, partly accommodating companies' pleas for helpwith an unexpected consequence of last year's tax law.
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Tax Cut Working Better Than Advertised
Despite concerns over trade disputes and a slowing global economy, the corporate tax rate cut enacted in December of 2017 continues to encourage the business investment that leads to higher productivity and higherwages for Americanworkers. Today the government reported that such investmentwas higher than it initially reported for the third quarter of the year.
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Businesses call for wider Japan tax reform after consumption tax rise
Japanese businesses are nervous that public pressure could again postpone an increase to the consumption tax rate, further delaying the overhaul of the tax system that theywant.
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Mauritius remains a favourite among treaty shoppers
Treaty shopping is still a common practice among taxpayerswhen investing in Africa, and Mauritius remains one of the best jurisdictions for minimising tax liabilities.
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Individual Finds Disconnect in Term Used in Interest, GILTI Regs
An individual has commented on a possible disconnect between the broad definition of interest in proposed section 163(j) regulations (REG-106089-18) and the narrower definition of interest expense in proposed regs (REG-104390-18) on global intangible low-taxed income regarding interest expense allocations.
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Revised Voluntary Disclosure Rules Extend Penalty Framework
New voluntary disclosure guidelines apply to both foreign and domestic disclosures and include a penalty framework and access to Appeals.
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Chaos Concerns Propel Global Digital Tax Discussions
Apprehension over a potential patchwork of digital taxation measures could compel countries to achieve consensus by 2020.
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APMA Sees No Fundamental Changes as a Result of BEPS Project
Predictions that the IRS's advance pricing and mutual agreement programwould face a surge in disputeswith foreign tax authorities emboldened by the base erosion and profit-shifting project have thus far failed to materialize.
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U.S. to Address Some Ordering Rules With PTI Guidance
Treasury's narrowed scope for forthcoming rules on previously taxed income (PTI)will include guidance on some of the ordering rules, but answers to other PTI questionswill have towait until the spring.
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Proposed FTC Regs Massively Complex, but Not Unexpected
The proposed foreign tax credit regulations include extremely complex rules regarding allocation of expenses, among numerous issues, but largely follow the approaches practitioners thought Treasurywould take.
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MEPs Debate Value Creation With Google and Facebook
Google and Facebook users do not create taxable value under existing international rules, company representatives told a European Parliament investigative committee.
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Poland to Issue IP Box, Exit Tax Guidance
The Polish Ministry of Finance has called for public input on forthcoming guidance addressing the specific rules for Poland's recently enacted exit tax and preferential regime for income from intellectual property.
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Ireland to Pull Kill Switch on Digital Services Tax
Ireland is set to formally vote against adopting a draft digital services tax (DST) directive at a key upcoming finance ministers meeting, effectively snuffing out any chances of the tax's EU-wide adoption.
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FTC Regs Provide Minimal Relief on Expense Allocation
Proposed foreign tax credit regulations take the edge off expense allocation but largely dismiss taxpayer concerns that allocating expenses to the global intangible low-taxed income basket results in residual tax beyond Congress's intent.