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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By Oliver R. Hoor and Keith O'Donnell
The 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.
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.
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.
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.
The 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.
The 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.
Robert Goulder examines whether reverse transfer pricing could become a viable method to avoid the base erosion and antiabuse tax provisions.
The 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.
The 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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