OECD–MNE Tax

Americas

US Treasury official says it is working with Congress to ensure Pillar Two does not negate tax benefits like R&D: Assistant Secretary for Tax Policy Lily Batchelder / US Department of the Treasury→

March 4, 2022

Africa

Pillar One rules should disallow deductions for losses occurring prior to implementation, an intergovernmental group of 54 developing economies says / The South Centre→

March 4, 2022

Africa

OECD Global Forum launches new trainer program for tax officials in Africa, Asia, and Latin America: OECD→

March 4, 2022

Americas

What every taxpayer should learn from Coca-Cola: Song / CrossBorder Solutions→

March 3, 2022

Europe

Transfer pricing in Germany: issues to monitor and address in 2022

March 3, 2022

Oliver Treidler and Tom-Eric Kunz, TP&C, analyze the current transfer pricing landscape in Germany, following the plethora of updates to regulations and administrative principles in 2020 and 2021, which has led to considerable uncertainty regarding tax audits as well as an increased compliance burden.

Americas

US President Biden urges 15% minimum corporate tax in State of the Union address: Barrett / YahooFinance→

March 2, 2022

Asia-Pacific

New UAE transfer pricing regulations to enhance UAE regional hub status

March 2, 2022

Mourad Chatar and Sarah Bahous, Value Square, discuss the transfer pricing implications stemming from the United Arab Emirates’ newly announced corporate income tax system.

Asia-Pacific

Bahrain, Romania deposit instruments of ratification for BEPS MLI with the OECD, joining 70 other countries; entry into force is June 1, for both countries: OECD→

March 1, 2022

Americas

A regulatory tax hike on US multinationals

February 28, 2022

Daniel Bunn, Tax Foundation, discusses why a meaningful tax hike for multinational companies has already been adopted while much of the policy focus has been on proposals embedded in the Build Back Better agenda, which still has not yet made its way through the US Congress.

Europe

International taxation: two-pillar plan and the OECD mainstream

February 28, 2022

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses the February 21 virtual “OECD Tax Talks” webinar to assess the world’s progress in implementing the historic OECD/G20 two-pillar international tax package.

Europe

Spain’s annual guidelines on tax and customs controls focus on transfer pricing issues

February 28, 2022

Abigail Blanco Vázquez and Mario Ortega, J&A Garrigues, S.L.P., discuss the Spanish tax agency’s January 31 publication of the general guidelines of the 2022 Annual Tax and Customs Control Plan, containing transfer pricing changes, including a new automated transfer pricing risk analysis system.

Africa

OECD releases third batch of transfer pricing country profiles for 28 jurisdictions: OECD→

February 28, 2022

More News

‘OECD Tax Talks’ presentation slides: OECD→

February 24, 2022

OECD launches public consultation on Pillar One draft model rules for tax base determination

February 23, 2022

Nyasha Nigel Machiri, HLB Zambia, discusses the OECD’s February 18 announcement that it is seeking public comment by March 4 on its draft model rules for tax base determinations under Amount A of Pillar One.

Americas

The applicability of the Spanish GAAR to conduit structures after the CJEU Danish cases

February 23, 2022

Aitor Navarro, Carlos III University, discusses the Spanish tax authorities’ December 16, 2021 publication of a panel report on the applicability of the domestic GAAR to a conduit arrangement aimed at benefiting from an exemption at source on the payment of interest income to EU residents.

Africa

Kenya: embracing the two-pillar approach

February 23, 2022

Samuel Okumu, Rödl & Partner Limited, discusses the OECD-Kenya Revenue Authority’s three-day workshop in Naivasha, Kenya in late January to assess Kenya’s efforts in enacting the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS).

More News

Public comments released on OECD draft rules for nexus, revenue sourcing under Pillar One Amount A (63 entries): Dropbox.com→

February 23, 2022

Asia-Pacific

Hong Kong announces plans to implement BEPS 2.0, introduce 15% domestic minimum tax for in-scope MNCs from 2024-25: Yuen / Marketing-Interactive.com→

February 23, 2022

Americas

Has the Indian tax administration removed the sheen from the ‘most favoured nation’ clause in its tax treaties?

February 22, 2022

Priyanshi Chokshi, Raghav Bajaj, and Vinita Krishnan, Khaitan & Co., analyze the ramifications of the Indian Central Board of Direct Taxes’ clarification of the applicability of the “most favoured nation” (MFN) clauses in Indian tax treaties through its February 3 circular.

More News

OECD seeks public comments by Mar. 4 on draft rules for tax base determinations under Amount A of Pillar One→

February 22, 2022

Europe

Spanish National Court challenges the application of an internal CUP in favor of the TNMM

February 22, 2022

Mario Ortega and Rubén López, J&A Garrigues, S.L.P. discuss the Spanish National Court’s December 20, 2021 decision resolving a case revolving around the selection and application of certain transfer pricing methods.

Americas

Largest MNEs can’t comply with requirements to track their transactions under OECD tax deal’s draft revenue sourcing rules, USCIB says: McDonald and Minor / USCIB→

February 18, 2022

Americas

US Senate Finance Committee Republicans write US Treasury Secretary with `alarming’ concerns over OECD tax plans: Crapo / US Senate Committee on Finance→

February 17, 2022

OECD launches public consultation on Pillar One draft model rules on revenue sourcing and nexus

February 10, 2022

Nyasha Nigel Machiri, HLB Zambia, discusses the OECD announcement that it is seeking public comment by February 18 on recently released draft model rules with respect to nexus and revenue sourcing under Amount A of Pillar One as part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the two-pillar solution.

Africa

Lesotho, Thailand, and Vietnam sign multilateral convention to implement tax treaty-related measures to prevent BEPS: OECD→

February 9, 2022

Europe

Montenegro introduces new landmark transfer pricing rules, corporate tax changes

February 1, 2022

Slobodanka Kolundžija, freelance tax advisor, discusses the Montenegrin parliament’s December 31 introduction of a new landmark set of transfer pricing rules, requiring companies to prepare and file transfer pricing documentation from . . .

Africa

UAE announces 9% corporate income tax rate, sets tone on regional corporate tax competition

January 31, 2022

Mourad Chatar and Sarah Bahous, Value Square, discuss the United Arab Emirates’ January 31 announcement that it will implement a federal corporate tax regime at a standard nine percent rate, which will apply to relevant businesses from . . .

Multinational

Global minimum tax safe harbor with simplified effective tax rate calculation for low-risk countries could ‘tremendously reduce reporting obligations and compliance costs for MNEs’: Döllefeld, Englisch, Harst, Schanz & Siegel / SSRN→

January 21, 2022

OECD transfer pricing guidelines get first update in five years

January 20, 2022

In the new 2022 edition of the OECD’s transfer pricing guidelines released on January 20, the OECD has made three significant additions and revisions to the guidelines for multinational enterprises and tax administrations, reflecting several enhancements developed over . . .

Austria

EU’s path forward on global minimum tax is under debate

January 18, 2022

EU member states are at odds on various issues related to the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing concerns about key aspects in a January 17 Economic and Financial Affairs Council . . .

Asia-Pacific

Taiwan highlights changes in new tax treaty protocol with UK

January 18, 2022

Taiwan’s Ministry of Finance on January 18 explained the changes in the new amending protocol to the UK-Taiwan tax treaty, which took effect on January 1 after entering into force on . . .

Americas

Poland transfer pricing laws under review to strengthen system against tax evasive behavior

January 14, 2022

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s participation since November in a project coordinated by the European Commission to reform Polish transfer pricing regulations; the project is planned to . . .

Americas

Switzerland will implement global minimum tax by constitutional amendment

January 13, 2022

The Swiss Federal Council on January 12 decided that it will implement the 15% global minimum tax agreed by the OECD Inclusive Framework through a constitutional amendment with an aim to ensure the measure comes into force as of January 1, 2024; the approach is intended to . . .

Africa

Swiss international tax update addresses OECD deal, treaties, MAP

January 12, 2022

Switzerland’s State Secretariat for International Financial Matters on January 10 issued a report on various ongoing tax projects, including the country’s take on the OECD deal, as well as the status of tax treaty negotiations, tax information exchange, mutual agreement procedure (MAP), and recent . . .

Americas

Barbados country-by-country reporting tax law takes effect

January 12, 2022

Barbados tax legislation enacting country-by-country reporting came into operation on December 31, 2021, following publication in the Official Gazette on . . .

Accounting

UK sets out approach to global minimum tax implementation

January 11, 2022

The UK government on January 11 opened a consultation on how it plans to implement and administer within the UK the OECD model rules on the internationally agreed 15% global minimum tax; the consultation also considers the introduction of a UK domestic minimum tax, as well as . . .

Africa

EU tax transparency directive: When turkeys vote for Christmas

January 10, 2022

Cédric Maheo, CWA Morocco, discusses how the EU directive on public country-by-country reporting for large multinationals, published in the Official Journal of the European Union on December 1, will give tax authorities in the developing world new data on multinationals operating in . . .

Accounting

OECD’s ‘complex’ minimum tax rules have ‘major policy issues,’ BIAC says

January 7, 2022

In a January 6 letter to the OECD, business advisory group Business at OECD (BIAC) criticizes “significant policy inconsistencies” in the OECD’s global minimum tax model rules that it considers “potentially fatal” to their operation; moreover, it contends efforts must be made to . . .

Europe

Finnish transfer pricing adjustment provision amendments are now in force

January 5, 2022

Marianna Santamala, Bird & Bird Attorneys Ltd, discusses the new amendments to the Finnish transfer pricing adjustment clause included in section 31 of the Finnish Assessment Procedure Act, which came into effect on January 1, 2022, and apply to tax years beginning on . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin