The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Archives: July 2021Subscribe
By Stephen Gardner
An influential EU panel has suggested using a mechanism designed to combat harmful tax practices to push EU member states into accepting a global minimum tax rate. Over 130 countries have agreed on a global minimum tax rate of “at least 15%" but four EU countries—Cyprus, Estonia, Hungary, and Ireland—have not signed up to the agreement, which was negotiated through the Organization for Economic Cooperation and Development.
By Jefferson VanderWolk
On July 1, 2021, the OECD-led Inclusive Framework on BEPS announced that 130 countries had agreed on revised outlines of a two-pillar plan calling in part for a reallocation of taxing rights regarding certain large multinational businesses. The author discusses the proposed reallocation in light of the U.S. Trade Representative’s recent reports on digital services taxes.
By Peter Flanagan
Bigger countries are using negotiations on global corporation tax reform to increase their own tax revenue at the expense of smaller nations, Ireland’s deputy prime minister said. “This isn’t just about tax justice and big companies paying their fair share,” Leo Varadkar told reporters in Dublin. “This is also about big countries trying to get a bigger share of the pie.”
By Christopher Condon, William Horobin, and Aoife White
U.S. Treasury Secretary Janet Yellen will press European Union officials in Brussels to reconsider their plan to propose a digital levy after securing the Group of Twenty’s endorsement for the principles of a global corporate-tax agreement. Yellen is in Brussels following the gathering of G-20 finance ministers and central bankers in Venice, which concluded with the group’s call to finish work on the global plan’s details by October.
By Aoife White
The European Union said that it would postpone its push for a controversial digital levy to focus on a negotiation over a broader minimum global tax deal struck by the world’s largest economies. The U.S. has lobbied against the levy on digital sales that was likely to hit Silicon Valley giants’ business in Europe. The EU had pledged to introduce a levy if there was no progress on a sweeping effort to tax corporations more uniformly. Such a pact now seems more likely after the Group of 20 endorsed the principles of a global-tax agreement.
By Naomi Jagoda
Finance officials in the Group of 20 (G-20) endorsed “key components” of a framework for an international tax overhaul that is a top priority of the Biden administration. The G-20 finance ministers and central bank governors announced their backing of major elements of the Organization for Economic Cooperation and Development’s (OECD) tax framework following a meeting in Venice, Italy. The framework calls for a global minimum tax for corporations of at least 15 percent.
By Paul Hannon and Giovanni Legorano
Finance chiefs from the Group of 20 leading economies endorsed an overhaul of the rules for taxing international companies, a landmark achievement of global cooperation after years of tensions. G-20 members have rarely been able to agree to such ambitious changes over the past decade of disputes over trade, investment and jobs, although they did work together to offset the economic impact of the Covid-19 pandemic. The tax agreement, negotiated earlier this month by 130 countries, has raised hopes that major economies can find common approaches to tackling other global problems, such as climate change and trade.
By Craig Elliffe
In this paper it is controversially suggested that international tax law is broader than the traditional view of most academics. In addition to domestic laws that cover cross-border transactions and double taxation agreements (or their multilateral counterparts) there is a special consensus international tax law (CITL) based on the institutions, instruments and interpretation implemented by international consensus. This paper explores what is meant by international tax law. The weight of opinion does not support the view that CIL presently creates any binding tax obligations on States. This paper proposes that there is, however, an emerging system based on common understandings, with the legal duties of cooperation and underpinning expectations of implementation which should be recognized as creating obligations upon States even though it does not constitute CIL.
By Hannah Brenton
U.S. economy chief Janet Yellen had successfully stalled EU plans for a digital levy and told national governments how to run their economies. Yet EU officials had nothing but effusive praise for their American visitor. “We could say that in terms of our relationships with the U.S. we have gone from a winter of discontent to a summer of cooperation,” Economy Commissioner Paolo Gentiloni told journalists. The European Commission confirmed it would bow to U.S. demands to put its plans on hold until the fall.
By Stephanie Soong Johnston
The European Commission’s decision to postpone its digital levy proposal is a positive development and will allow countries to finalize the details of a two-pillar global tax reform agreement, according to a top OECD official. “In the end, everyone will have to play his or her part in the sense that no country will do something that will be inconsistent with this global deal when it’s done,” OECD Deputy Secretary-General Masamichi Kono said July 14 during a webcast organized by the Atlantic Council Geoeconomics Center.
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