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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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International Tax News Blog

Archives: November 2019

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  • Pillar 1 Profit Formula Should Approximate Arm's-Length Standard

    Tax AnalystsBy Ryan Finley

    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.

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    By Ryan Finley, posted on Thursday November 28, 2019
  • Crown Dependencies Issue New Substance Guidance for IP Companies

    Tax AnalystsBy Ryan Finley

    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.

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    By Ryan Finley, posted on Thursday November 28, 2019
  • ECOFIN to Discuss Public CbC Reporting

    Tax AnalystsBy Elodie Lamer

    Ambassadors 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.

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    By Elodie Lamer, posted on Thursday November 28, 2019
  • Outside the Box: In Praise of Reverse Transfer Pricing

    Tax AnalystsBy Robert Goulder

    Robert Goulder examines whether reverse transfer pricing could become a viable method to avoid the base erosion and antiabuse tax provisions.

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    By Robert Goulder, posted on Thursday November 28, 2019
  • OECD Must Link Pillar 1 Profits or Face More Double Tax Risks

    Tax AnalystsBy Stephanie Soong Johnston

    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.

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    By Stephanie Soong Johnston, posted on Thursday November 28, 2019
  • Up to 15 Multinationals Leave Philippines;Tax Reform Law Cited

    Tax AnalystsBy William Hoke

    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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    By William Hoke, posted on Thursday November 28, 2019
  • A Unified Approach to International Tax Consensus

    Tax AnalystsBy Allison Christians

    In this article, the author considers the OECD’s “unified approach” proposal on the tax challenges of the digital economy, and questions whether it represents a true international consensus.

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    By Allison Christians, posted on Thursday November 28, 2019
  • Navigating the EU-OECD Harmful Tax Competition Jungle

    Tax AnalystsBy Barry Larking

    In this article, the author tracks the development of the EU and OECD actions to combat harmful tax competition and assesses the current state of play.

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    By Barry Larking, posted on Thursday November 28, 2019
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    Retail banking argues for exclusion from pillar one

    By Danish Mehboob

    The retail banking sector wants to be exempted from the pillar one proposals under the OECD’s digital tax plan because of existing, heavy financial regulations and possible mismatches with OECD policy considerations under pillar one.

    By Danish Mehboob, posted on Monday November 25, 2019
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    Amazon: OECD should adopt VAT principles to simplify digital tax plan

    By Mattias Cruz Cano

    Amazon has suggested the OECD should adopt existing VAT principles to simplify the compliance and administration of its digital tax proposals under pillar one. It believes VAT rules on customer location could help, but warns that privacy laws and VPNs mean it can only be part of the solution.

    By Mattias Cruz Cano, posted on Monday November 25, 2019


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