by Laurence Field (Crowe Clark Whitehill)Harmonization lies at the core of many of the European Union's governing principles: could Brexit be the catalyst for greater harmonization among the remaining Member States?
This article explores recent attempts at European harmonization, assessing Franco-German drives for closer cooperation and integration on tax; analyzing the European Commission's latest re-launch of the common consolidated corporate tax base (“CCCTB”); and looking at whether the U.K.’s decision to leave the European Union (“EU”) will be a catalyst for greater EU harmonization among the remaining Member States.
by Stephanie Soong Johnston (Tax Notes)Additional drafts of revised and new transfer pricing guidance will come out in mid-2017, and final value added tax and goods and services tax guidelines will be published in April, according to OECD tax officials. The officials gave updates on other work related to the base erosion and profit-shifting project, the G-20 mandated work on tax certainty, and automatic information exchange.
by Rick Mitchell (Bloomberg BNA)The OECD effort to rebuild the global tax system should focus on practical work that benefits the international tax community rather than trying to get as many countries as possible around the table, a former Treasury official said.
The OECD’s so-called inclusive framework for implementing the four minimum standards of the international project to fight base erosion and profit shifting has brought in many countries that aren’t members of the OECD, which launched the BEPS project, or even of the Group of 20 nations, which endorsed BEPS outcomes, Robert Stack, a former U.S. deputy assistant Treasury secretary for international tax policy, noted March 27. The G-20’s members account for about 85 percent of the global economy, he said.
by Shi-Chieh "Suchi" Lee (PWC)International Tax News is designed to help multinational organisations keep up with the constant flow of international tax developments worldwide. Among the topics featured in this month's edition are:
- Israeli budget reduces corporate tax rates and expands corporate tax incentives
- Portugal's 2017 state budget law
- Further increase of the Austrian research premium
- The US IRS Rev. Proc. 2017-23, Process for filing form 8975, country by country report
by Reuven S. Avi-Yonah and Haiyan Xu (University of Michigan Law School)The new OECD Multilateral Instrument to amend tax treaties (MLI) is an important innovation in international law. Hitherto, international economic law was built primarily on bilateral treaties (e.g., tax treaties and BITs) or multilateral treaties (the WTO agreements). The problem is that in some areas, like tax and investment, multilateral treaties proved hard to negotiate, but only a multilateral treaty can be amended simultaneously by all its signatories.
by Reuven S. Avi-Yonah and Martin Vallespinos (University of Michigan Law School)Since the SCM agreement was enacted in 1995, the global leadership in the field of STZs has shifted from the OECD to the WTO.
The WTO general agreement includes a broad set of policy goals that goes beyond trade relationships, but its legal framework has been systematically narrowed to the task of assuring market access, non-discrimination, and fairness in trade. Other relevant issues that has impacts on trade, such as for example harmful tax competition or tax base erosion, has not been sufficiently weighted and has been treated as secondary items.
by Joe Kirwin (Bloomberg BNA)The European Parliament’s special Panama Papers investigative committee concluded its four-day “fact-finding” visit to the U.S. with its chairman calling on the U.S. to close its tax loopholes.
In a March 24 telephone interview at the conclusion of the U.S. visit, the committee‘s chairman, German lawmaker Werner Langen, told Bloomberg BNA that EU members “have made appeals to the U.S. federal government and Delaware that there needs to be a clampdown on anonymity by introducing beneficial ownership registers.”
by Stephen Morris (Bloomberg)Europe’s largest banks routed 25 billion euros ($27 billion) through tax havens in 2015, about a quarter of their profit, amid an international crackdown on corporate tax avoidance, according to a report by Oxfam International.
The 20 biggest lenders paid no tax on 383 million euros of profit posted in seven tax havens that year, while booking 4.9 billion euros of earnings in Luxembourg, more than the U.K., Sweden and Germany combined, Oxfam and the Fair Finance Guide International said Monday. The study was based on data released under new European Union regulations requiring banks to report earnings on a country-by-country basis.
by Stephanie Soong Johnston (Tax Notes)G-20 finance ministers have responded favorably to the OECD and IMF's joint report on tax certainty, according to the OECD's tax chief, who added that the OECD will engage with countries bilaterally to discuss the results of the business survey on which the report is based.
by Greg Castello (Financial Executives)A complex matrix of treaties and multi-country agreements govern international trade. Similarly, there’s no single international law governing international taxation. With no global authority to set a worldwide standard, each country is free to set its own standards. The resulting patchwork of national rules and regulations makes international tax planning and compliance more than a little complicated. Companies must carefully structure operations and define a strategy for each country in order to maximize legal tax advantages.