Int'l Tax News

Portugal is planning to turn itself into a low-tax haven for young adults by offering a decade of tax breaks to people starting their careers in an effort to halt a growing brain drain.

Donald Trump has said he will end “double taxation” for millions of Americans living overseas if he wins the US presidential election next month.

Business groups and associations have responded forcefully in comments criticizing Treasury’s disregarded payment loss regs, arguing that the government lacks authority to issue the rules, as the Supreme Court made clear in Loper Bright.

The Swiss government expressed resistance to using financial transaction taxes to finance the country’s old age pension system.

Proposed corporate alternative minimum tax regs’ provisions pertaining to foreign-parented multinational groups, which have caught some tax experts by surprise, were drafted to ensure parity between foreign and domestic entities, according to Treasury.

Robert Goulder comments on the European Commission’s reinvigorated state aid case against the Netherlands and Ikea.

Mindy Herzfeld examines the saga of European state aid cases and the costs of the Court of Justice’s recent decision in European Commission v. Ireland for the U.S. government — and its taxpayers.

The EU Council legal service recently warned member states that the draft transfer pricing directive is getting in the way of an agreement on a nonbinding joint transfer pricing forum.

Brazilian President Luiz Inácio Lula da Silva has issued a provisional measure providing for a domestic minimum tax intended to be qualified as in line with the OECD’s global anti-base-erosion rules.

Hafiz Choudhury outlines the progress of draft Article XX on fees for services within the U.N. model tax convention’s evolution away from reliance on physical presence.

The European Union said negotiations for a new corporate tax treaty at the United Nations were potentially duplicating those taking place at the Organization for Economic Development and Cooperation in Paris.

As the OECD continues to promote Pillar Two, balancing the goal of fostering tax fairness with the need to avoid excessive compliance burdens is a challenge.

Rachel Reeves, the UK chancellor, is not expected to hit private equity bosses with the top 45p tax rate in this month’s Budget, as she looks for a compromise deal to close tax “loopholes” that does not drive investors out of Britain.

The European Commission is acting on a complaint by foreign-controlled companies operating in Hungary that the country's discriminatory retail tax regime puts them in a much higher tax bracket than domestic retail franchises operating there.

The European Commission has referred Cyprus, Poland, Portugal, and Spain to the EU’s highest court after warning them twice about their slow adoption of the EU’s directive for implementing global minimum tax rules.

EU member states have agreed to impose tariffs of up to 45 per cent on imports of Chinese electric vehicles, ratcheting up the biggest trade dispute between the economic superpowers in a decade.

Ten years of case law involving the EU banking union show that the EU has legal grounds to levy a contribution on companies in exchange for services, according to a European Parliament study.

Fabian Kratzlmeier argues that pillar 2’s group approach disregards the interests of creditors and minority shareholders, and he explores how long-standing concepts of civil, corporate, and bankruptcy law could be used to protect those interests within the global anti-base-erosion framework.

Ryan Finley explains why the EU member states may want to reconsider their objections to a transfer pricing directive after European Commission v. Ireland.

Christine Lagarde, president of the European Central Bank, said an EU capital markets union could be achieved through a 28th regulatory regime, including on taxation.

The U.S. Chamber of Commerce has expressed strong support for another American business group’s legal challenge against the undertaxed profits rule in the Belgian Constitutional Court, saying the measure is “fundamentally flawed.”

Jeffery M. Kadet responds to a recent article on reforms to the subpart F and global intangible low-taxed income regimes, commending the authors’ efforts but arguing that their proposals should be carefully considered, given whom they would benefit.

The OECD has published guidance for tax administrations on exchanging information on crypto assets. The document, dated Oct. 2, features a user guide for the XML schema used in the automatic exchange of information under the Crypto-Asset Reporting Framework, or CARF.

EU member states’ ambassadors are ready to adopt an official position on the future of the U.N. tax negotiations that urges more analysis and consensus-based decision-making.

Robert Goulder examines the European Commission’s state aid case against Nike in light of the recent Apple judgment.

J. Clifton Fleming Jr., Robert J. Peroni, and Stephen E. Shay explain how the subpart F regime and the global intangible low-taxed income regime together contribute to a long-running decline in domestic manufacturing employment, and they argue that the best approach to fixing the problem is worldwide taxation without deferral, not pillar 2.

Notice 2024-16 announces the government’s intent to issue regs to provide an adjustment to a domestic acquiring corporation’s basis of acquired CFC stock for covered inbound transactions. Laura E. Williams, Jennifer Franceschini, and Raza Janjua of PwC explain how the narrow definition of covered inbound transactions and the limitations outlined in Notice 2024-16 may leave taxpayers exposed to double taxation in many situations, and argue that future regulations should provide for expanded relief.

Ireland revealed plans Tuesday to extend a range of tax benefits to attract risk finance into the country as part of a pre-election budget. The Department of Finance is proposing to extend the Relief for Investment in Corporate Trades benefits by two years, a budget document outlining tax measures said, putting them into effect until Dec. 31, 2025.

David G. Chamberlain responds to Lee A. Sheppard’s analysis of the EU Court of Justice’s ruling in the Apple state aid case and argues that the Court’s ruling was correct.

Argentina’s economic reform law has significant tax implications for various industries. The law, issued by decree on Aug. 22, includes a large investments incentive system known as RIGI. A key feature of the measure is a stability provision for a 30-year period, encompassing tax, customs, legal, and regulatory incentives.

Corporate income tax rates across the world stabilized in 2023 after years of decline, according to a new report from the OECD summarizing international taxation trends.

The French government is weighing fresh taxes on corporates to cut the country’s budget deficit, newspaper Le Monde reported.

Thomas Horst explains and illustrates his evaluation of the effect of the OECD/G20’s pillar 2 minimum tax rules on U.S. multinational enterprises and on U.S. federal tax revenue.

The former president’s efforts to compel companies to remain in the United States had limited success while he was in the White House.

Ryan Finley explains why the Court of Justice was wrong to assume that its understanding of OECD transfer pricing and profit attribution guidance is the only reasonable interpretation.

Treasury is not overly concerned with practitioner worries stemming from a lack of carryforwards for direct foreign tax credits and book-to-tax income recognition timing differences under its corporate alternative minimum tax proposed regs.

The Democratic presidential nominee outlined her economic plans, including tax credits to boost next-generation industries, during a speech in Pittsburgh.

Germany’s Growth Opportunities Act, applicable as of Jan. 1, highlighted a disparity between the German legislature’s application of the arm’s-length principle for intra-group financing versus OECD transfer pricing guidelines for multinational companies and tax administrations. This has created substantial uncertainty for multinationals, leaving many unresolved questions about application of the new tax legislation.

Nigeria urged the United Nations on Tuesday to begin negotiations toward a global tax treaty opposed by wealthier countries because its work would overlap with that of the OECD.

The US Treasury Department is working on guidance to apply a set of OECD rules that seek to simplify the way businesses value certain intercompany transactions, a department official said Tuesday. The implementation of the rules, known as Amount B, is on the list of Treasury’s priority guidance projects, said Brenda Zent, special adviser on international taxation at Treasury.

The Republican presidential nominee uses tax breaks and tariff threats in a bid to persuade foreign companies to shift production.

The former president highlighted his plans to increase tariffs and reduce corporate taxes for businesses that make products in the United States.

Robert Goulder comments on the final decision of the EU’s Court of Justice on the state-aid claim against Ireland.

The Netherlands and Finland both published draft legislation to update their respective global minimum tax laws to include recent guidance from the OECD.

Switzerland is mulling OECD rules aimed at simplifying transfer pricing methods for certain transactions, also known as Amount B, under the global tax deal. Swiss Competent Authority member Ronny Rosenblatt said that Switzerland may use Amount B as a safe harbor and commit to accept it when dealing with covered countries that are using it.

Tax reforms driven by OECD and UN initiatives are reshaping the international tax landscape and require African economies, governments, and businesses to adapt to an evolving global tax environment.

Lee A. Sheppard examines the recent decision by the EU’s Court of Justice in the Apple transfer pricing case, arguing that it contradicts the Court’s own precedent and OECD guidance.

Mindy Herzfeld examines recently proposed dual consolidated loss regs and questions whether the regs are justified by the legislative history, or whether Treasury has exceeded its authority under Loper Bright Enterprises Inc. v. Raimondo.

Rémi D. Gagnon assesses the U.S. experience with the concept of economic substance and draws lessons for the successful development of this concept in Canada in light of the structural differences between the two systems.