Posted on
IP Factor Highlighted at Cloud Sourcing Reg Hearing
The IRS and Treasury are contemplating the proper attribution method to determine the source of income for cloud transactions and are questioning how to evaluate relevant factors like intangible property.
Posted on
Is the U.S. BEAT a Digital Services Tax?
Patrick Driessen argues that the similarity between the U.S. base erosion and antiabuse tax and digital services taxes undermines the United States’ criticism of DSTs.
Posted on
Does the U.S. Exception Threaten Pillar 2?
Adam Kern analyzes how treating global intangible low-taxed income as an income inclusion rule will affect the stability of pillar 2.
Posted on
OECD Updates G20 on International Tax Cooperation Developments
The OECD on July 17 published a report — prepared ahead of the July 17-18 meeting of G20 finance ministers and central bank governors in South Africa — regarding recent developments in international tax cooperation, including its support of various G20 priorities such as tax transparency and the implementation of the base erosion and profit-shifting minimum standards.
Posted on
AI and Guidance Review on OECD’s Agenda
The OECD plans to adapt its transfer pricing guidelines to new realities like global mobility and artificial intelligence and to develop a common understanding of terms that are often disputed, an official said.
Posted on
DSTs Expected to Play a Bigger Role in Trade Talks
The lines between tax and trade policy are likely to become increasingly blurred as the Trump administration shifts its attention to disarming overseas digital services taxes, observers say.
Posted on
U.N. Tax Protocol on Services Could Build on Amount A, G24 Says
The U.N. tax framework convention’s early protocol on services should incorporate fractional apportionment or formulary apportionment similar to amount A of pillar 1 of the OECD’s two-pillar global tax reform plan, the G24 said.
Posted on
Can a Company Levy Finance the EU Budget?
The design of an own resource to finance the EU budget as a contribution levied on high-turnover companies raises legal questions.
Posted on
Good Intentions, Bad Tools: A Case for Repealing the UTPR
Pramod Kumar Siva and William H. Byrnes explain why the UTPR, formerly known as the undertaxed profits rule, is an unlawful extraterritorial tax that contravenes legal norms, generates economic distortions, and diminishes international tax cooperation.
Posted on
Four in Five Polled Europeans Want MNEs to Pay Minimum Taxes
A new Eurobarometer shows that 80 percent of Europeans polled want large multinational enterprises to pay a minimum amount of tax in each of their countries of operation, an idea that finds a majority in all member states.
Posted on
U.N. Model Tax Convention 2025: New Wine in New Bottles – But What’s Really New?
Muhammad Ashfaq Ahmed examines changes to the U.N. Model Tax Convention 2025 from their genesis, evolution, and development, to their finalization, approval, and future implications from both an international tax law and international political economy perspective.
Posted on
Moving On From Retaliatory Taxes
Mindy Herzfeld examines the developments that led to the recent G7 agreement to respect the U.S. tax regime as “a side-by-side system” with the OECD’s pillar 2 and what that means for the future of digital services taxes and tax multilateralism more broadly.
Posted on
EU Says GILTI Pushdown Might Defeat Pillar 2 Purposes
The EU has “a quite negative view” on the United States' proposal to credit its minimum tax rules when calculating their qualified domestic minimum top-up taxes under pillar 2, according to a top European Commission official.
Posted on
Don’t Try to Salvage the Wreck of Pillar 2
In a letter to the editor, Jefferson VanderWolk argues that pillar 2 should be abandoned rather than an attempt be made to salvage it.
Posted on
Nigeria’s Quest to Broaden Its Tax Base
Nana Ama Sarfo discusses Nigeria's new tax reform legislation and its emphasis on base broadening and tax enforcement.
Posted on
Goodbye, Section 899, We Hardly Knew Ye
Robert Goulder comments on the recent G7 agreement regarding pillar 2 and the withdrawal of proposed section 899.
Posted on
Ghost of Revenge Tax Looms Over G7’s Pillar 2 Deal
Governments across the globe breathed a sigh of relief when Republicans dropped section 899, but slow progress on the terms of the deal reached by the G7 could see it return with a vengeance.
Posted on
German Economy Minister Rejects Colleague’s Call for Digital Tax
Germany’s economy minister has rejected the idea of imposing a digital tax on U.S. technology companies that the minister of state for culture had said the government was drafting in May.
Posted on
Irish Finance Minister Questions What G7 Deal Means for Pillar 2
Irish Finance Minister Paschal Donohoe said there are still outstanding questions about how the G7 deal on pillar 2 will affect competition between the EU and the United States and the future of the law.
Posted on
European Parliament to Examine a Levy on Artificial Intelligence
The European People’s Party's advocate for copyright issues in the European Parliament has suggested a 7 percent levy on artificial intelligence companies that use copyright-protected works to compensate rightsholders.
Posted on
BRICS Countries Endorse U.N. Tax Convention Work
BRICS member states said they support work on a U.N. tax convention and its role in promoting better cooperation and transparency to address issues like illicit financial flows and tax evasion by the superrich.
Posted on
Is Implementing a Global Wealth Tax Possible?
Simone Decè considers whether implementing a global wealth tax is practical, analyzing the challenges that different proposed solutions present.
Posted on
A Quick Look at the New Streamlined FDII Deduction
Martin A. Sullivan examines the foreign-derived deduction-eligible income provision in the reconciliation bill.
Posted on
Developing Countries’ Tax Systems Center Stage at U.N. Conference
Several high-income countries and civil society groups committed to improving developing countries' domestic tax systems to increase revenue collection there at a major U.N. development financing conference.
Posted on
Argentina and Peru’s Positions on the Multilateral Instrument
Lucas de Lima Carvalho examines the status of the OECD’s multilateral instrument in Argentina and Peru.
Posted on
Tax Goals and U.N. Finance Conference
Nana Ama Sarfo reviews the tax-related provisions of the outcome document from the U.N.'s Fourth Financing for Development Conference and the Sevilla Platform for Action.
Posted on
China Allows Tax Credit to Foreign Investors Reinvesting Profits
Foreign investors that reinvest their dividends from Chinese entities into qualifying domestic companies will be allowed a 10 percent tax credit, the government announced June 30.
Posted on
The Rise and Stall of the EU’s State Aid Campaign Against Transfer Pricing
Shafi U. Khan Niazi and Richard Krever examine how the European Commission attempted to stop intra-Europe transfer pricing schemes by reversing private rulings that facilitated profit shifting through preferential tax treatment in the profit destination jurisdictions.
Posted on
EU Commission Doesn’t Foresee Need to Change Pillar 2 Directive
The European Commission says the G7 provisional agreement on pillar 2 is based on a permanent safe harbor shielding U.S. firms, but the lack of details leaves stakeholders drawing various conclusions.
Posted on
U.N. Tax Convention Work to Focus on Cross-Border Taxing Rights
The U.N. committee negotiating a framework convention on international tax cooperation will focus on the fair allocation of taxing rights — especially over multinationals — and the prevention and resolution of tax disputes at its next sessions.
Posted on
Two if by Sea: The Role of Tax in the U.S. Shipping Revolution
Guy A. Bracuti examines President Trump’s Executive Order 14269, “Restoring America’s Maritime Dominance,” and the tax provisions of the Shipbuilding and Harbor Infrastructure for Prosperity and Security for America Act of 2025.
Posted on
G7 Deal Shields U.S. Firms From Some Pillar 2 Minimum Tax Rules
The United States’ G7 counterparts have agreed to not apply their pillar 2 global anti-base-erosion (GLOBE) rules to U.S.-parented groups, but those companies would still be in scope of qualified domestic minimum top-up taxes.
Posted on
Canada Rescinds Digital Services Tax to Preserve U.S. Trade Talks
Canada will rescind its digital services tax as part of its efforts to continue trade negotiations with the United States, Canadian Prime Minister Mark Carney said June 29.
Posted on
U.K. Plans July Pillar 2 Guidance Amid U.S. Revenge Tax Reversal
HM Revenue & Customs welcomed the removal of the section 899 revenge tax in the U.S. One Big Beautiful Bill Act (H.R. 1), adding it hopes to publish new U.K. pillar 2 guidance in July.
Posted on
The Logic of the Revenge Tax
Wei Cui argues that the One Big Beautiful Bill Act’s formerly proposed section 899, targeting “unfair” foreign taxes, was more sensible than many observers initially perceived, and that, if seen as a restrained deployment of U.S. market power, it represented a defensible and ultimately acceptable approach for addressing the undertaxed profits rule and digital services taxes.
Posted on
Senate Fixes to the House Bill and More
Mindy Herzfeld examines the changes made by the Senate to some provisions of the One Big Beautiful Bill Act, saying that the Senate’s version of the bill improves on the retaliatory tax measures introduced by the House and would simplify and improve the U.S. international tax regime.
Posted on
China Decrees Tax Reporting Requirement for Internet Platforms
The Chinese government has issued a decree regulating tax-related information that internet platform companies are required to submit.
Posted on
Frankenstein-Pay: Does PayPal’s 95 Percent Foreign Income Since 2013 Cause a Monstrous Periodic Adjustment? Part 2
Stephen L. Curtis continues his analysis of PayPal’s cost-sharing arrangement, explains how the cost-sharing regulations can be exploited to possibly shift billions in U.S. profits offshore with little or no IRS detection or enforcement, and explores how the agency’s position could be changing.
Posted on
OECD Global Mobility Effort Aims to Ease PE Tax Woes
Employees are increasingly on the move in the wake of the COVID-19 pandemic, and observers say the OECD is well placed to design templates to make it easier for countries, companies, and employees to determine tax residency.
Posted on
Remote Work vs. Corporate Income Tax: Navigating the New Normal
Raffaele Petruzzi and Argyro Myzithra explore the implications of remote working arrangements for a multinational enterprise's permanent establishment and its transfer pricing issues.
Posted on
Final ECOFIN Tax Report Drops Pillar 2 Wording
EU finance ministers adopted a progress report on tax issues and deleted several of its points on pillar 2 of the global tax deal, including the need for its implementation worldwide.
Posted on
Senate Offers Up ‘Defanged’ Remittance Tax, but Critics Remain
Senate Republicans addressed key concerns about the scope of a proposed excise tax on remittances in their version of the reconciliation tax bill, but the overarching policy still has its detractors.
Posted on
Overseas Investors Demur on U.S. Private Markets in Light of Trump’s ‘Revenge Tax’
A portion of the ‘one, big, beautiful bill’ could lead to a new tax on foreigners’ U.S. investments in private equity and credit. Some of them are treading cautiously.
Posted on
Will OBBBA Reform Duty Drawbacks?
Robert Goulder comments on the practice of duty drawbacks and a recent legislative proposal to limit their reach.
Posted on
This Loophole Buried in Trump’s Bill Is Anything but Beautiful
A loophole in Trump’s policy bill would continue to encourage offshoring.
Posted on
Senate GOP Opts for International Tax Regime Redesign
Senate Republicans unveiled a robust set of international corporate tax reforms in their version of the reconciliation tax bill, including adjustments to the House-passed version and a suite of new provisions.
Posted on
MEPs Sink Report on Development Financing Despite Tax Consensus
Members of the European Parliament rejected a report calling for a strong U.N. tax process in the context of the next international conference on financing development, though that specific provision was consensual.
Posted on
Countries Signal Tax Commitment Ahead of U.N. Finance Conference
U.N. countries agreed to prioritize international tax cooperation ahead of a major development financing conference, with an emphasis on improving domestic resource mobilization for developing countries.
Posted on
The Silent Tax: A Study of Inflation’s Hidden Effects on Effective Taxation
Oliver R. Hoor explains the relationship between taxation and inflation.
Posted on
New Own Resource Proposals Are Needed, EU Presidency Says
The EU Council's Polish presidency urged the European Commission to revise its plan to fund the bloc's budget after member states pushed back on the current package of proposed levies yet again.