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International Tax News Blog

  • Vietnam's Decree 91 features tax incentives for manufacturing and technology

    by Meredith McBride (International tax review)

    Vietnam’s Decree 91 on VAT and corporate income tax (CIT) came into effect on October 15 2014. It includes provisions on deductible expenses, tax incentives for manufacturers and high-technology firms, a reduction in the paperwork required for tax filing and in the corporate tax rate for agricultural businesses, which are all applicable for the 2014 reporting year.

    For the story, go here.

    By McBride, Meredith , posted on Friday October 24, 2014
  • Income of Foreign Subsidiaries: A Review of the Basic Analytics

    by Alvin C. Warren (Tax Analysts)

    Alvin C. Warren reviews the basic analytics of deferral and exemption systems for taxing the income of foreign corporate subsidiaries, highlighting some relationships that are not always appreciated in policy discussions.
    For the article, go here. (Subscription required)

    By Warren, Alvin C., posted on Thursday October 23, 2014
  • U.K. Tax Rules That EU Panned Win Ally at Highest Court

    by Stephanie Bodoni (Bloomberg)

    European Union tax regulators suffered a setback as an aide to the bloc’s top court sided with the U.K. in a clash over the nation’s corporate tax system.

    Rules that EU authorities criticized for making it almost “impossible” for companies to claim tax relief on non-resident subsidiaries are justified, an adviser to the EU Court of Justice said today.

    For the story, go here.

    By Bodoni, Stephanie , posted on Thursday October 23, 2014
  • OECD gives cautious welcome to Knowledge Box tax scheme

    by Colm Kelpie (

    Pascal Saint-Amans, the director of the Centre for Tax Policy and Administration at the Paris-based Organisation for Economic Cooperation and Development (OECD), told the Irish Independent it was "common sense" for the Government to wait for the conclusion of an examination of patent box schemes elsewhere by Europe before moving.
    For the story, go here.

    By Kelpie, Colm , posted on Thursday October 23, 2014
  • 'Ireland Inc' summit: US-Irish business mergers 'are not about avoiding tax' says ambassador

    by Gavin McLoughlin (

    Countries that work together like Ireland and the US "need to be cognisant" of the impact their tax policies have on each other, new US Ambassador to Ireland Kevin O'Malley said in a speech yesterday.

    He said cross-border mergers can make the Irish and American economies stronger, but that "these transactions should be driven by genuine business strategies and economic efficiencies, not a desire to shift the tax residence of the parent entities simply to avoid taxes".
    For the story, go here.

    By McLoughlin, Gavin , posted on Thursday October 23, 2014
  • Noonan Says Ireland Aims to Play to Win' On Taxes, Welcomes U.S. Action on Inversions

    by Bloomberg Daily Tax Report

    Ireland's finance chief defended his country's tax policies that have encouraged numerous American companies to route profits through his country, but said he also welcomes recent U.S. efforts to stifle a wave of corporate inversion deals.
    Finance Minister Michael Noonan, speaking at the second Finance Tax Policy Conference in Dublin, said the 12.5 percent corporate tax rate set in Ireland's recently announced budget provides investors with certainty as many countries are changing their policies as part of global tax changes spearheaded by the Organization for Economic Cooperation and Development, under the direction of the Group of 20.
    For the story, go here. (subscription required)

    By Bloomberg Daily Tax Report, posted on Friday October 24, 2014
  • Practitioner: OECD Documentation Draft Will Double Companies' Compliance Burden

    by Kevin A. Bell (Bloomberg Daily Tax Report)

    The Organization for Economic Cooperation and Development's proposed country-by-country reporting template, master file and local file portend a doubling of the transfer pricing compliance burden of multinational companies worldwide, a London practitioner said.
    Patrick Trapp of EY LLP said the Sept. 16 draft guidance under Action 13 of the international plan to combat base erosion and profit shifting constitutes a significant change in transfer pricing documentation—“both in focus and in detail, and for most parts of the world.”
    For the story, go here. (subscription required)

    By Bell, Kevin A. , posted on Friday October 24, 2014
  • Massive EU-Nation VAT Losses Highlight Need for Major Changes, Commission Says

    by Joe Kirwin (Bloomberg)

    A new study concluding that European Union member states lost more than $200 billion in value-added tax revenue in 2012 underlines the need for changes to the patchwork VAT system, according to the European Commission.
    Based on the commission-sponsored study, the difference between what should have been collected by EU member states and what was actually collected—the “VAT gap”—was $224 billion.
    In addition to widely different approaches taken by EU member states when it comes to rates on certain products, the commission said the report, issued Oct. 22, proves EU member states' continued rejection of proposals for more harmonization has significant fiscal costs.
    For the story, go here. (subscription required)

    By Kirwin, Joe , posted on Friday October 24, 2014
  • ECJ Advocate General Rejects Ruling In Landmark Marks & Spencer' Case

    by Joe Kirwin (Bloomberg Daily Tax Report)

    The European Court of Justice should abandon the terms established by the landmark 2005 Marks & Spencer judgment allowing for cross-border corporate group tax relief, the European Union's top legal adviser said in an opinion.
    If the EU high court adheres to the Oct. 23 opinion (C-172/13) by ECJ Advocate General Juliane Kokott, which happens in 80 percent of all cases, it would dismiss a European Commission legal challenge brought against the United Kingdom in an effort to force it to properly apply the Marks & Spencer judgment.
    The surprise legal opinion could restrict the fundamental freedom of establishment for companies that is one of the pillars of the EU single market, according tax experts.
    For the story, go here. (subscription required)

    By Kirwin, Joe , posted on Friday October 24, 2014
  • Death and taxes: Is the corporate tax rate killing the U.S. economy?

    by Ann Duncan (Thomson Reuters)

    “In this world nothing can be said to be certain, except death and taxes.” Benjamin Franklin
    “The only difference between death and taxes is that death doesn’t get worse every time Congress meets.” Will Rogers
    The IRS and the U.S. Treasury last month announced plans to squelch the trend for businesses to seek foreign tax shelters through corporate inversions. But why are companies fleeing? Because the current corporate tax rate is oppressive. (See BioWorld Today, Sept. 24, 2014.)
    For the blog post, go here.

    By Duncan, Ann , posted on Friday October 24, 2014