Int'l Tax News

Reuven S. Avi-Yonah casts doubt on whether bilateral investment treaties offer investors a viable shield from pillar 2’s qualified domestic minimum top-up tax, in response to a recent Tax Notes article.

Mindy Herzfeld explains the uneven effect of the Tax Cuts and Jobs Act’s carrot-and-stick approach to encouraging U.S. multinationals to bring valuable intellectual property back to the United States.

Companies in scope of digital services taxes will probably have more permanent establishments in jurisdictions with DSTs if OECD pillar 1 rules are enacted, according to a Joint Committee on Taxation economist.

EU member states are at odds over how to coordinate the application of double taxation agreements to accommodate the tax complexities of cross-border telework.

Manufacturers have two years to move their critical mineral supply chains away from foreign entities of concern if they want to qualify for the new clean vehicle tax credits, Treasury announced in final regulations.

Błażej Kuźniacki and Edwin Visser explain the difficulties for non-advanced economies trying to attract foreign direct investment while also adhering to new pillar 2 rules, and offer suggestions for new international approaches that could help create a more level playing field for all economies.

Canada’s digital services tax might cause U.S. companies to lose up to $2.3 billion annually, and if the United States doesn’t push back, the “global contagion” of DSTs will spread, a tech industry group said.

Roy Clemons argues that the United States should replace its quasi-territorial tax system and proposes a framework that taxes domestic and multinational corporations at the same statutory tax rate on a country-by-country basis.

Ryan Finley explains why withdrawing the cost-sharing regulations wouldn’t further the policy goals of cost-sharing critics.

Robert Goulder comments on a recent Congressional Research Service report on pillar 1 and digital services taxes.

Martin A. Sullivan examines newly released IRS data that reveal surprising shifts in where U.S. multinationals book profits and losses, with some of the usual suspects absent and Gibraltar topping the tax haven list.

Honda is the latest automaker to announce a multibillion-dollar investment in Canada, bolstered by new investment tax credits introduced by the federal government to support the green transition.

Vladimir Starkov and Alexis Jin explain their study on the effect of amount A on U.S. corporate income tax revenue.

A future United Nations Framework Convention on International Tax Cooperation should help countries reform their domestic tax systems and avoid duplicating work on international tax reform, the European Union said ahead of UN tax discussions in New York.

The committee is considering topics such as how the UN framework will approach taxing multinational companies and wealthy individuals, digital taxation, taxation of cross-border transactions, combating tax-related illicit financial flows, and using tax to address environmental challenges.

EY authors discuss the implications of EU’s new carbon tax that may significantly impact developing economies.

EU member states have presented a common approach to discussions about a U.N. framework convention on international tax cooperation, but several countries are still not ready to discuss proposals.

The US Treasury Department and business groups are at odds with Australia over its taxation of software — and that could prompt higher taxes, higher prices, and maybe even a rethink by US companies over how they’ll do business there.

Business groups are critical of Vietnam’s financial support plan to soften the impact of the global minimum tax on multinationals, saying it’s too vague and narrow in scope, with only large projects able to meet its eligibility conditions.

Nana Ama Sarfo outlines some of the discussions at a recent Senate Budget Committee hearing on offshore tax avoidance.

Ireland has forecast a budget surplus of €8.6 billion ($9.2 billion) this year, citing anticipated record corporation tax receipts in a boost for the country that is in the process of setting up its sovereign wealth fund.

Martin A. Sullivan examines the generous provisions of Bermuda’s new corporate income tax and how they interact with the OECD’s pillar 2 rules.

The European Commission is still open to the possibility of proposing mandatory publication of the effective tax rates of large corporations operating in the EU, according to a top EU tax official.

Peter Hongler and Simon Habich explain that upcoming U.N. negotiations should look to establish the institutional groundwork for a more credible evolution of the international tax system, recognizing that a global consensus may not be imperative across all tax-related domains, and instead should strive for global inclusivity.

Sweden’s finance ministry is aiming to pass a suite of tax breaks to enhance the country’s competitiveness and to support business and individuals who continue to struggle economically.

Building consensus takes time, so the quick pace of the U.N.’s work on the terms of reference for a new framework convention on international tax cooperation is worrisome, a top EU tax official said.

While implementing a minimum effective tax rate of 15% under the OECD’s Pillar Two initiative, Singapore looks to stay competitive to businesses by granting credits to offset corporate income tax payable by companies with qualifying expenditures for approved projects.

A report commissioned by EU leaders on the future of the single market calls for a harmonized tax framework and says allowing exceptions to the unanimity rule could take a bite out of tax avoidance.

EU leaders have broadly backed a roadmap for improving the bloc’s competitiveness, a blueprint that includes using tax incentives to meet its objectives.

Ratification of an international treaty that would reallocate taxing rights over the profits of the world’s largest companies is “not the most likely scenario” despite its possibly being ready for signing in June, a former OECD tax chief said.

As president of this year’s Group of 20 nations, Brazil is prioritizing implementation of a global minimum wealth tax on billionaires as a means to fund efforts to combat rising temperatures and poverty in low and middle-income countries.

An EU value-added tax exemption for companies’ foreign operations that aren’t considered “fixed establishments” may need to be redefined in the context of increased automation.

A proposed change to a United Nations model tax treaty is being debated for its potential for double taxation and increased compliance burdens for companies, while it is intended to expand the use of gross taxation to more kinds of cross-border business services and eliminate physical presence tests.

EU heads of state are scheduled to discuss how to strengthen the bloc’s single market and competitiveness, and some member states are determined to debate even the most politically sensitive proposals, with potential tax implications.

G-24 countries are hoping to engage multilaterally on a range of tax issues, including corporate income tax and consumption tax, and shore up domestic revenue amid debt woes.

Canada will start applying a proposed 3% tax on the world’s biggest technology companies this year, despite threats from American lawmakers to carry out trade reprisals against a levy that will primarily hit US firms.

 Former Italian prime minister Enrico Letta said European Union countries should better harmonize their tax systems as part of a major effort to boost the bloc’s single market.

The European Union may have the opportunity to amend anti-tax avoidance rules and develop a new tax information exchange rule so that companies don’t have to report multiple times in different EU countries for minimum tax compliance purposes.

The “Future Made in Australia” plan, which will form part of Australia's upcoming budget and address the green energy transition, will contain strict tests for receiving tax credits and subsidies.

European Commission President Ursula von der Leyen is unleashing a barrage of trade restrictions against China as she seeks to follow through on a pledge to make the EU a more relevant political player on the global stage.

Canada’s federal budget includes a new 10% tax credit on the capital cost of buildings used for EV manufacturing — but only if companies make a significant bet on locating other portions of their supply chains within the country.

Large U.S. companies are pressing lawmakers to revive expired tax breaks for research and development spending, as a political stalemate keeps some finance executives wrestling with those investments.

The US is looking at consistent implementation of the global minimum tax rules across countries through a peer review process to ensure its foreign tax credit can be distributed appropriately to companies in regimes that qualify under the review.

Jurisdictions may have missed a key deadline to reach agreement on the text of the pillar 1 multilateral convention, but the OECD remains optimistic about prospects for a deal, a top OECD official said.

The two-pillar OECD tax reform plan doesn’t go far enough to help developing countries, so the G-24 is hopeful for more progress under a U.N. framework convention for international tax cooperation, the group’s director said.

Nana Ama Sarfo reviews some responses to Australia's most recent public country-by-country reporting consultation and notes how the measure raises larger questions about international standardization.

EU leaders plan to adopt a draft statement calling for the harmonization of corporate tax law to advance the Capital Markets Union, but the European Commission’s meetings with tax officials tell a different story.

Reuven S. Avi-Yonah suggests that the EU adopt the pillar 1 three-factor formula for BEFIT and apply it to large multinationals operating in the EU.

Martin A. Sullivan examines how companies are addressing the effects of pillar 2 in their financial reports, using the “Magnificent 7” to show various approaches.

Mindy Herzfeld cautions that the United States’ tax base could erode in the wake of a global push for broad-based withholding taxes on services.