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The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
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INSIGHT: Fiat State Aid Case—Impact on Luxembourg
By Oliver R. Hoor and Keith O'DonnellThe General Court of the EU has upheld the decision of the European Commission in the Fiat case, confirming that a tax ruling by the Luxembourg tax authorities conferred an advantage which constituted illegal state aid. Oliver R. Hoor and Keith O’Donnell of ATOZ Tax Advisers (Taxand Luxembourg) discuss the Court’s decision and what it will mean for Luxembourg going forward.
To read more go here Subscription RequiredFrance Endorses OECD Pillar 1 Global Tax Overhaul
By: Stephanie Soong Johnston
France strongly supports the OECD pillar 1 proposal for allocating more taxing rights to market countries and suggests a 12.5 percent rate for global minimum taxation under pillar 2, according to a top official.
To read more go here Subscription RequiredEconomic Analysis: How Much New Taxable Profit for Market Countries
By: Martin Sullivan
In economic analysis, Martin A. Sullivan examines the OECD's attempt to rewire the international source rules so that more taxable profits are allocated to market jurisdictions than currently allowed under the arm's-length rules.
To read more go here Subscription RequiredHow Could the United States Implement a Global Tax Deal?
By: Mindy Herzfeld
Mindy Herzfeld considers what steps the United States would need to take for the OECD’s pillar 1 proposals to become workable for the IRS, as well as for other tax authorities when applied to U.S. taxpayers.
To read more go here Subscription RequiredPillar 1 Profit Formula Should Approximate Arm's-Length Standard
By Ryan FinleyThe formulas for calculating local distributors’ profit under pillar 1 of the OECD’s two-pillar project on taxing the digital economy should produce results that generally align with the arm's-length standard, according to business representatives and practitioners.
To read more go Subscription RequiredCrown Dependencies Issue New Substance Guidance for IP Companies
By Ryan FinleyThe three British crown dependencies have jointly released updated guidance for applying each jurisdiction’s new economic substance rules, with new sections on core income-generating activities of intellectual property companies, shipping, and the insurance industry.
To read more go Subscription RequiredECOFIN to Discuss Public CbC Reporting
By Elodie LamerAmbassadors and tax experts from EU countries recently spoke out against the decision of the Finnish EU Council presidency to try to reach an agreement on public country-by-country reporting by qualified majority.
To read more go Subscription RequiredOutside the Box: In Praise of Reverse Transfer Pricing
By Robert GoulderRobert Goulder examines whether reverse transfer pricing could become a viable method to avoid the base erosion and antiabuse tax provisions.
To read more go Subscription RequiredOECD Must Link Pillar 1 Profits or Face More Double Tax Risks
By Stephanie Soong JohnstonThe OECD must address the lack of interaction between three categories of company profit that would be taxed under proposed new global tax rules, or else double taxation risks could increase, a trade representative warned.
To read more go Subscription RequiredUp to 15 Multinationals Leave Philippines;Tax Reform Law Cited
By William HokeThe head of a Philippine business association said a tax reform program might be one of the reasons why 10 to 15 multinational companies' regional operating headquarters have pulled out of the country.
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