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Early responses to the OECD set dividing lines

By Josh White 

The first responses to the OECD on its public consultation on the digital economy show divisions continue, with some calling for an expansion of the FAR analysis or reverting to the G24 plan.The Paris-based organisation held a public consultation on the October report on its pillar one proposals. Sources close to the OECD hope the consultation will demonstrate that there is support for the proposals. This could be crucial for the OECD to push ahead with its ambitious project. So far, the signs have been mixed, but not necessarily bad for policymakers.

Global Minimum Tax Faces Coordination, Income Base Hurdles

By Alex M. Parker

Officials around the globe hope that a minimum corporate tax is the best approach to tackling avoidance and complex tax planning, but developing a universal standard to measure tax payments could be a daunting technical challenge.

GILTI: The Co-operative Potential of a Unilateral Minimum Tax

By Susan C. Morse

Prior to the Tax Cuts and Jobs Act of 2017 (TCJA), the US allowed US parented multinationals to delay indefinitely their payment of US corporate income tax on non-US income earned by non-US corporate subsidiaries (CFCs). The TCJA revoked this permission through the enactment of a unilateral, current minimum tax on the “global intangible low-taxed income” (GILTI) of CFCs. The post-TCJA US international tax law generally imposes current US tax on CFC income subject to reductions for foreign income taxes paid or accrued. This US regime supports the continued existence of a corporate income tax and presents an opportunity to co-ordinate the details of corporate income tax systems globally. The author argues that similarity among systems, for instance with respect to rate, timing and base, would further strengthen the corporate income tax and perhaps support innovations such as formulary apportionment. US tax administrators, non-US governments and taxpayers will each play a role in negotiating the details of international corporate income tax law going forward and in determining whether and on what terms these details converge.