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  • BEPS Primer: Past, Present, and Future

    By: Jeffery M. Kadet

    In this two-part article, the author updates his examination of the initial OECD base erosion and profit-shifting project, and he considers the process and potential success of BEPS 2.0. This first installment examines the origin of the BEPS project, its objectives, and how it may proceed in the future. The second installment will focus on BEPS 2.0.

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    By Jeffery M. Kadet, posted on Tuesday July 21, 2020
  • Authority Questions Arise for FDII Heightened Substantiation

    By: Andrew Velarde

    Treasury’s decision to base its substantiation requirements for some foreign-derived intangible income transactions on those of two other tax code provisions may lead to taxpayers questioning the authority upon which it rests.

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    By Andrew Velarde, posted on Wednesday July 22, 2020
  • The Trouble With ‘Pillars’ in International Tax Policy

    By: Lucas De Lima Carvalho

    In this article, the author discusses the OECD’s two-pillar approach to taxing the digital economy. He focuses on the narrative of “pillar-building” in international tax policy and the difference between building consensus and manufacturing consent.

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    By Lucas De Lima Carvalho, posted on Wednesday July 22, 2020
  • OECD Sketches Out Progress on Global Tax Reform Blueprints

    By: Stephanie Soong Johnston

    The OECD has made good progress on designing a global tax reform plan, but stakeholders may need to be realistic about the prospect of countries agreeing on that plan by year-end, officials said.

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    By Stephanie Soong Johnston, posted on Thursday July 23, 2020
  • U.K. Digital Services Tax Becomes Law, Stoking Trade Tensions

    By: Stephanie Soong Johnston

    The U.K digital services tax has become law, setting the stage for escalating trade war tensions between the United Kingdom and the United States, which is investigating whether the tax discriminates against American business interests.

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    By Stephanie Soong Johnston, posted on Thursday July 23, 2020
  • Cost-Sharing Arrangements May Have Less Appeal Post-TCJA

    By: Ryan Finley

    The Tax Cuts and Jobs Act’s amendments to the definition of intangible property and codification of the aggregation and realistic alternative principles may discourage taxpayers’ use of cost-sharing arrangements in the future.

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    By Ryan Finley, posted on Thursday July 23, 2020
  • European Parliament to Renew Push for EU Taxes

    By: Jean Comte

    Members of the European Parliament are threatening to reject the 2021-2027 EU budget if member states don’t make a clear commitment to introducing new EU-wide taxes to finance it.

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    By Jean Comte, posted on Thursday July 23, 2020
  • Kenya's DST Could Force Out Digital Gaints

    International Tax Review

    By: Mattias Cruz Cano

    Multinational enterprises (MNEs) that are struggling to decipher Kenya’s vague digital services tax (DST) legislation may decide to exit the country instead of risking non-compliance

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    By Mattias Cruz Cano, posted on Wednesday July 22, 2020
  • Indonesia Defends Digital Tax Plans Against U.S. Investigation

    By: Stephanie Soong Johnston

    The Indonesian government intends to implement an electronic transaction tax that would take into account consensus on a global approach to modernize corporate tax rules, and remains “open to dialogue” about its plans.

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    By Stephanie Soong Johnston, posted on Thursday July 16, 2020
  • BEPS Initiatives May Hit Ireland Harder Than Expected

    By: Kiarra M. Strocko

    The OECD’s base erosion and profit-shifting initiatives and international tax changes may affect Irish corporate tax revenue over the medium term by more than the €2 billion previously estimated by Ireland's Department of Finance.

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    By Kiarra M. Strocko, posted on Thursday July 16, 2020


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