Peter Hongler, University of St. Gallen, predicts Switzerland will likely change its constitution because of Pillar Two—a proposal to address global profit shifting by imposing a global minimum tax of at least 15%—and took its first step in that direction by opening a public consultation on the OECD/G20 minimum tax plan for multinationals on March 13.
Allan Lanthier, a former advisor to the Canadian government, warns it’s time to hit the emergency brake on the OECD’s model rules for Pillar Two; while close to 140 countries agreed to the October 2021 framework, they didn’t agree to these new model rules, which introduce a lot of uncertainty and complexity.
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 . . .
Bijal Ajinkya and Raghav Kumar Bajaj, Khaitan & Co, discuss the Swiss tax authority’s August 13 confirmation that dividends received by an Indian resident from a Swiss company will be subject only to a 5% withholding tax rate in Switzerland, but if India does not reciprocate, the Swiss reserve the right to . . .
New York City Economist, Dr. J. Harold McClure, discusses the latest edition of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released April 27, which includes some useful observations on the nature of intangible assets, yet it has a very sparse discussion of the evaluation of intercompany royalty rates . . .
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