Multinational

Cyprus

Cyprus, Saudi Arabia deposit MLI ratification documents, North Macedonia signs

January 29, 2020

Cyprus and Saudi Arabia have deposited legal instruments with the OECD ratifying a multilateral tax treaty known . . .

Denmark

Denmark reverses course, supports EU digital deal should OECD effort fail, prime minister says: Morten Buttler / Bloomberg→

January 29, 2020

Digital Economy

UK will introduce DST from April 2020 despite OECD plea for delay, Treasury official says: Anna Menin / CityAM→

January 27, 2020

Americas

Apple’s Tim Cook says international tax system needs revision: Padraic Halpin / Reuters→

January 21, 2020

Americas

France to delay DST, US to delay tariffs to allow more time for international tax deal, unnamed French officials say: James Politi, Mehreen Khan, Victor Mallet, & Martin Arnold / Financial Times→

January 21, 2020

Africa

The train has left the station: OECD tax officials discuss state of play for pillar one and two

January 20, 2020

Oliver Treidler of TP&C GmbH, Berlin discusses a January 16 tax conference sponsored by the German Federation of Industry which featured discussion and updates by OECD leadership and a German tax official concerning the negotiations surrounding pillar one and two and potential updates to tax dispute avoidance and dispute resolution mechanisms. . . .

Americas

US proposal for optional pillar one tax is a “non-starter” French minister says: Reuters→

January 17, 2020

IBOR reform: why transfer pricing professionals need to start paying attention

January 15, 2020

Casimir Leuridan and Melanie Beirens of Zanders, Belgium, discuss the implications of the discontinuance IBOR, scheduled for the end of 2021, on transfer pricing professionals . . .

Multinational

New framework for selecting and adjusting foreign comparables for developing countries offered by Paris NGO: Bert Steens, Christof Beuselinck, Matthis Pettutshnig & Sébastien Gonnet / TPED→

January 13, 2020

OECD publishes updated country-by-country reporting guidance, notification requirements

December 30, 2019

The OECD on December 23 released additional interpretative guidance on country-by-country . . .

Digital Economy

EU Parliament adopts resolution supporting an EU-wide digital tax should global negotiations fail: European Parliament→

December 22, 2019

Asia-Pacific

Jordan signs BEPS MLI tax agreement to fight tax avoidance

December 22, 2019

Jordan on December 19 signed the . . .

Multinational

Professors say that magnitude of BEPS problem is overstated due to incorrect accounting treatment of indirectly owned foreign affiliates: Jennifer Blouin & Leslie A. Robinson / SSRN→

December 22, 2019

Europe

Multilateral tax treaty to enter into force for Liechtenstein

December 22, 2019

Liechtenstein on December 19 deposited its instrument of acceptance of . . .

Americas

Officials discuss aligning Brazil’s transfer pricing laws with OECD standards

December 20, 2019

Francisco Lisboa Moreira, a tax partner, Bocater Advogados, São Paulo, discusses Wednesday’s public joint-meeting between OECD and Brazil’s tax authority which again addressed aligning Brazil’s transfer pricing regime of Brazil with OECD standards . . .

Africa

US Treasury official defends “pillar one” safe harbor proposal for new global tax rules

December 20, 2019

A senior US Treasury official on December 19 said that the US is recommending that the OECD’s proposal for a “unified approach to pillar one” be rewritten as an optional safe harbor rule because even a watered-down version . . .

Americas

Brazilian court rules that Oracle subsidiary may deduct outbound royalty payments

December 16, 2019

Francisco Lisboa Moreira, a tax partner at Bocater Advogados, São Paulo, discusses the Oracle case, decided by Brazil’s highest administrative tax court on December 3 . . .

Americas

Honduras joins “Inclusive Framework on BEPS” addressing taxation of multinational groups

December 11, 2019

Honduras has joined the “Inclusive Framework on BEPS” becoming the . . .

Outlook for global consensus on an international tax update appears “bleak,” tax researchers conclude: Rasmus Corlin Christensen & Martin Hearson / Roosevelt Institute→

December 11, 2019

Europe

Why the EU Commission won’t appeal the Starbucks judgment

December 10, 2019

Dimitrios Kyriazis, Head of the Law Faculty at the New College of the Humanities, London, discusses the Commission’s decision to not appeal the Starbucks State and the implications of the Court’s judgment for transfer pricing in Europe . . .

Digital Economy

OECD holds consultation on “pillar two” global tax for multinationals, pledges continued work on “pillar one”

December 9, 2019

The OECD on December 9 held a public consultation in Paris, providing a forum for stakeholders to express their views on how to best design a “pillar two” global minimum tax on multinational group profit, also known . . .

Americas

France rejects US plan to turn pillar one of tax rewrite into a “safe harbor,” says EU should negotiate digital tax if global agreement falls through: Tom Ozimek / Epoch Times→

December 9, 2019

Africa

Is the US about to blow up the OECD’s compromise “pillar one” plan for taxing multinational group profit?

December 5, 2019

In a surprising development, US Treasury Secretary Stephen Mnuchin has revealed that the US no longer supports key elements of the OECD’s compromise proposal to overhaul the rules for allocating multinational group profit and related taxing. . .

Africa

OECD releases 186 comment letters on proposal for global minimum tax on multinational group profit

December 3, 2019

The OECD today released 186 comment letters in response to its request for assistance in the design of a global minimum tax on multinational group profit. The OECD also released the, , ,

Asia-Pacific

Australia releases synthesized text of tax treaties with Ireland, India reflecting MLI changes

December 3, 2019

The Australian government on November 29 released the synthesized texts of tax . . .

Developing countries’ favored formulary approach is superior to OECD proposal which cobbles together parts of incompatible proposals, professor asserts: Sol Picciotto / ICTD→

December 3, 2019

Africa

Tunisia signs multilateral country-by-country reporting agreement

November 29, 2019

Tunisia on November 27 signed the . . .

Africa

Tax researcher disagrees with OECD’s Ben Dickenson, says developing countries should negotiate global tax rewrite as a block to even out power imbalance: Joy Ndubai / ICTD→

November 29, 2019

Americas

OECD releases reports assessing cross-border tax dispute resolution in seven countries

November 29, 2019

OECD, on November 28, released peer review reports assessing cross-border tax . . .

Africa

OECD celebrates Global Forum’s 10th anniversary

November 29, 2019

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI) in Manno, Switzerland discusses the 10th anniversary celebration of the OECD-led Global Forum on Transparency and Exchange of Information where more than 386 delegates from more than 142 jurisdictions met in Paris . . .

Africa

Kenya, Oman sign multilateral tax treaty

November 28, 2019

Kenya and Oman on November 28 signed a multilateral tax treaty designed to combat. . .

Digital Economy

Paris consultation reveals little unity on OECD’s “unified approach” for taxing multinational groups

November 26, 2019

More than 100 speakers lined up at a November 21–22 Paris consultation to share their views on the OECD Secretariat’s compromise proposal to update to the rules for allocating multinational group profits and related taxing rights among countries, known as the “unified approach to pillar one.” The OECD’s . . .

Americas

OECD’s digital tax plan would raise little revenue for France, Germany, US, and China, French Council of Economic Analysis concludes: Financial Times→

November 19, 2019

Digital Economy

The GloBE puzzle: a debate way beyond use of financial accounts

November 18, 2019

Dr. Leopoldo Parada of the University of Leeds School of Law discusses the OECD’s global anti-base erosion (GloBE) proposal . . .

Digital Economy

OECD official disputes Professor Christians’s assertion that “unified approach” aims to shut down discussion of proposals contrary to powerful countries’ interests, says goal is to find common ground among countries: Ben Dickinson / ICTD→

November 18, 2019

Americas

OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes

November 18, 2019

The OECD today requested input from taxpayers to assist in an assessment of the timeliness and efficiency of the cross-border tax dispute resolution process in Aruba, Bahrain, Barbados,. . .

Digital Economy

OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing multinationals

November 17, 2019

The OECD on November 15 published more than 300 comment letters that respond to its request for feedback. . . .

The United Nations’ effort to shape global transfer pricing policy

November 16, 2019

George L. Salis, Principal Economist and Tax Policy Advisor at Vertex, Inc., King of Prussia, Pennsylvania, discusses the United Nations’ international tax and transfer pricing work, including the outcome of the 19th Session of the UN Committee of Experts on International Cooperation in Tax Matters, held October 15-18 in Geneva . . .

Asia-Pacific

G-24 opposes OECD Secretariat’s Pillar One compromise, seek greater allocation of profits to market and no exclusion for B2B transactions: Gireesh Chandra Prasad / Livemint→

November 15, 2019

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