Int'l Tax News

The EU Council’s Belgian presidency has persuaded some reluctant member states to accept a previously rejected deal with the European Parliament on the reclassification of digital platform workers.

In the wake of a significant and surprising district court decision holding the Corporate Transparency Act unconstitutional, practitioners expect the case to influence other challenges to the beneficial ownership reporting regime.

Tax authorities in Africa and Ukraine said technical assistance from the OECD in transfer pricing has resulted in higher revenue and improved compliance.

Pierce O’Reilly, head of business and international taxes at the Organization for Economic Cooperation and Development, noted that the minimum tax’s substance-based income exclusion rule will continue to support investment into low-capacity countries that tend to offer significant corporate investments.

Mindy Herzfeld examines how the United States can increase research and development and keep the resulting intellectual property stateside.

Martin A. Sullivan examines Form 10-K data from multinational pharmaceutical companies indicating that recent tax policy changes haven’t induced them to shift profits back to the United States, and he explores why that is a different story for tech companies.

Richard S. Collier and Ian F. Dykes explain the new rules released by HM Revenue & Customs on the transfer pricing risk framework and detail the relationship with the OECD Transfer Pricing Guidelines and the base erosion and profit-shifting project.

House taxwriters coalesced over their worries about the impact of the OECD global tax deal’s approach to digital services taxes but found little common ground across the aisle on whether the U.S. response should be to scrap participation or stick with the talks.

Low-capacity jurisdictions may not benefit from the OECD’s optional framework to simplify transfer pricing for some business transactions, because of a lack of data and administrative resources available to determine the revenue companies owe from such transfer pricing.

After 10 years in the European Parliament, Paul Tang, chair of the EP's subcommittee on tax matters, won't be running for a third term, leaving the future direction of the FISC unclear.

In Solar New US Holding Corp. v. Commissioner, a Tax Court challenge that could have implications for other rules, a company argues that the statutory repeal of the downward attribution exception makes the definition of a controlled foreign corporation under anti-inversion regulations invalid.

Lucas de Lima Carvalho examines how the “best practices” of international tax law developed and highlights the need for healthy skepticism toward this term.

Spotify Premium subscribers in France will soon get a price increase due to additional costs on music streaming services imposed by the government, as part of the CNM Tax, the company says in a statement.

Dubai, the Middle East’s financial hub, issued a decision to impose a 20% annual levy on the taxable income of foreign banks not based in the emirate’s international financial center.

US Republican lawmakers say the OECD’s multilateral tax treaty produces a loss of revenue to other countries, including China, and express concern the treaty is not effective to curb the proliferation of digital services taxes.

So-called phantom foreign direct investment, often undertaken through shell special purpose vehicles, has declined sharply since 2021, the European Commission said, noting the U.S. Tax Cuts and Jobs Act’s major effects on cross-border financial flows.

U.S. negotiators on pillar 1 are working on a more robust outcome that would provide more tax certainty and a mandatory amount B, sometimes referred to as phase 2, according to a Treasury official.

Revised profit allocation rules under pillar 1 of the OECD’s two-pillar global tax reform plan could have cost the United States as much as $4.4 billion in 2021, according to caveated estimates from the Joint Committee on Taxation.

The UK government will abolish the non-dom tax status and replace it with a "modern, simpler and fairer residency-based system," Chancellor of the Exchequer Jeremy Hunt says in an effort to raise tax revenues.

The UK proposed a variety of tax breaks for small businesses in its Spring 2024 budget released Wednesday, along with plans to curb tax avoidance, implement reporting rules for crypto assets and new measures to regulate tax advisors.

Senior Economist for The Tax Foundation says the UN should prioritize harmonization, reducing complexity, and cross-border investment to increase international tax cooperation.

Robert Goulder comments on one of Liberty Global’s multiple disputes with the IRS.

Had the OECD’s Pillar One proposal been in place during 2021, it would have cost the Treasury $1.4 billion, according to a new government analysis.

Trade groups have warned the Australian Taxation Office that its draft software royalty rules do not properly distinguish between payments on copyright articles and contravene preexisting international norms regarding the taxation of software.

Reuven S. Avi-Yonah advocates for Congress to adopt a general antiabuse rule to combat loopholes formed by the voluminous tax code.

Sol Picciotto, Jeffery M. Kadet, and Bob Michel analyze and compare the two proposals for a subject-to-tax rule to be included in tax treaties, one from the U.N. Tax Committee and the other from the G20/OECD inclusive framework on base erosion and profit shifting.

Jeremy Hunt wants UK retail investors to help revive the fortune of the country’s ailing stock market by creating an ISA, a tax-free savings account, for investing in UK equities.

The World Trade Organization agreed to extend a moratorium on e-commerce tariffs for two years after marathon negotiations in Abu Dhabi, while failing to secure deals on other contentious trade issues including a crackdown on agriculture and fisheries subsidies.

According to the National Foreign Trade Counsel and other industry groups, Australia’s draft ruling to tax payments for software and intellectual property is “overly broad”. The ruling targets goods and services that are often made up of many components, and applying a withholding tax to the entire payment is overreaching.

The EU’s carbon border adjustment mechanism taxes carbon-intensive imports to prevent a flood of cheap imports from countries with highly polluting industries, but only a fraction of EU companies expected to report emissions did so by an early deadline.

Chancellor of the Exchequer Jeremy Hunt has considered scrapping Britain’s non-domiciled tax, which allows about 70,000 people to avoid paying tax on their overseas earnings.

Covington’s Lauren Ann Ross analyzes advantages of the OECD International Compliance Assurance Program compared with advance pricing agreements and audit adjustments.

The OECD is on track to finish its multilateral tax treaty to reallocate taxing rights by March, and the global minimum tax will start in more than 35 countries this year. Estimates provide the treaty will reallocate $200 billion per year and increase revenues by at least $155 billion annually.

European Commission enforcement of Pillar Two rules for EU nations creates implementation challenges for countries and multinationals, PwC’s Will Morris, Giorgia Maffini, and Steven Kohart say.

Canada defended plans to enact a digital services tax against a potential economic reckoning from the US on Thursday, pointing to Washington’s tolerance for similar measures elsewhere.

Gabriel Zucman, who helped Elizabeth Warren develop a wealth tax plan for her 2020 US presidential campaign, is promoting a proposal for a global minimum wealth tax aimed at international coordination to tax the rich and fight poverty.

A group representing West African tax administrations is concerned the OECD’s recently published guidance on transfer pricing rules lack a definition for low-capacity jurisdictions and qualitative scoping criteria.

The OECD is considering developing a multilateral convention to resolve disputes related to the application of the global minimum tax, a top official for the organization said.

Implementation of the OECD’s global tax treaty is stalling due to political opposition in the US and tax negotiations by the UN influenced by developing nations.

 A tax deduction on interest in both the US and Singapore effectively lowers after-tax borrowing costs on bonds issued in Singapore.

The OECD’s latest report to simplify transfer pricing is complex and fails to confirm certain provisions, Imke Gerdes and Richard Fletcher of Baker McKenzie say.

New Zealand will not adopt the Organization for Economic Development’s new transfer pricing rules for bringing goods into the country, and instead continue to rely on its own rules.

The Bahamian government has announced its plans to implement a 15 percent corporate income tax in response to the OECD’s two-pillar international tax reform plan, anticipating tax revenue to exceed $140 million annually.

Other factors should be considered before the United States is blamed for a potential failure of pillar 1 of the OECD’s two-pillar global tax reform plan, an Estonian Ministry of Finance official said.

Andrea Di Gialluca and Davide Cotroneo explain the interaction between Italy’s research and development credits set in place to promote innovation and competitiveness in Italy, and imposition of the OECD’s pillar 2.