What We're Reading–MNE Tax

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

Asia-Pacific

South Korea to extend R&D tax incentives to technologies related to carbon neutrality, including carbon capture and renewable energy, as well as for rare earth elements facing supply shortages: Yonhap / The Korea Herald→

January 6, 2022

Americas

US failure to adopt tax changes included in stalled budget bill to align with OECD minimum tax would result in significant shift in tax revenue from US to foreign countries and increased double taxation: Reuven Avi-Yonah / LinkedIn→

December 30, 2021

Cyprus

Cyprus postpones deadline for submitting local country-by-country report for 2020 from 31 December 2021 to 31 January 2022: Cyprus tax department→

December 23, 2021

Asia-Pacific

Taiwan tax agency states that foreign businesses’ fixed places of business in Taiwan that sell services to domestic business entities must issue uniform invoices and file and pay business taxes: R.O.C. Ministry of Finance→

December 21, 2021

Asia-Pacific

Cyprus and Jordan signed tax treaty on December 17 that is based on OECD and UN models and incorporates base erosion and profit shifting (BEPS) minimum standards: Cyprus Ministry of Finance→

December 21, 2021

Asia-Pacific

Japan 2022 tax plan adopts tax incentives to boost employee pay through new deductions for companies that increase wages; declines to adopt capital gains tax hike or carbon tax: Nikkei Asia

December 14, 2021

Cyprus

Cyprus finance minister announces plan to increase corporate tax rate next year from 12.5% to 15%, in line with OECD deal, and expects minimal investment impact: Financial Mirror→

December 10, 2021

Multinational

Corporate tax rates dropped in 17 countries in 2021 (including Chile, Tunisia, and France) and increased in just three (Argentina, Bangladesh, Gibraltar), continuing 40-year global downward trend in rates: Sean Bray / Tax Foundation→

December 9, 2021

Americas

Bahamas reportedly urged by IMF to get ahead of global tax deal and establish 15% corporate tax rate to avoid ‘reputational risks’ to economy and ensure revenues go to Bahamian government: Neil Hartnell / The Tribune→

December 9, 2021

Africa

Kenyan High Court reviewing whether country’s tax treaties should be invalidated for enabling abusive tax avoidance and restricting tax authority’s ability to collect taxes: Kamau Muthoni / The Standard→

December 7, 2021

Americas

US corporations seek more exemptions from proposed minimum corporate ‘book tax,’ including for pension plans, depreciation – to supplement planned carve-outs for R&D, other investments: Laura Weiss / Roll Call→

December 7, 2021

Africa

African Tax Administration Forum official urges African countries to review tax incentives in light of OECD deal to assess whether they would still be effective or merely cede tax rights: Ibrahim Apekhade Yusuf / The Nation→

December 7, 2021

Europe

EU adoption of public country-by-country reporting translated into drop in markets, especially for MNEs with low effective tax rates, suggesting investor concern about reputational risks: Müller, Spengel & Weck / SSRN→

December 6, 2021

Americas

US proposed ‘163(n)’ interest limitation must stay in budget bill – despite lobbying attempts to strip it – to discourage MNE excessive, base-eroding interest deductions against US taxable income: FACT Coalition→

December 3, 2021

Asia-Pacific

Taiwan signs tax treaty with South Korea, seeks trade agreements with India and Australia: Lin Chia-nan / Taipei Times→

December 2, 2021

Americas

Cayman official sees no big problem for territory in OECD tax deal, which will not affect Cayman’s ‘bread and butter’ investment funds but MNEs with minimal Cayman exposure: Michael Klein / Cayman Compass→

December 2, 2021

Estonia

Estonia’s support for OECD tax deal is conditioned on ensuring that EU implementing rules affect only large in-scope multinationals and ‘leave the rest of our existing system untouched,’ Finance Minister says: Estonian government→

December 1, 2021

Americas

US-Turkey competent authority agreement on exchange of country-by-country reports signed on November 24: US Internal Revenue Service→

December 1, 2021

Africa

Kenya proposes requiring multinationals with revenues exceeding KES 2.5 billion (USD 22 million) to disclose country-by-country information beginning in January in bid to tackle tax avoidance: Allan Odhiambo / Nation→

November 29, 2021

Multinational

Global minimum tax’s potential to put a floor on tax competition hinges on technical issue of how substance-based carve-out is incorporated into ‘effective tax rate’ definition: Michael P. Devereux / Centre for Business Taxation→

November 29, 2021

Americas

US Congress should cap value of corporate tax incentives – if concern is excessive use of such incentives to avoid tax – rather than creating new, problematic tax on book income: Howard Gleckman / Tax Policy Center→

November 23, 2021

Europe

Isle of Man and Ireland signed tax treaty protocol November 19, underling countries’ commitments to ‘latest international standards in respect of Base Erosion and Profit Shifting’: Isle of Man government→

November 19, 2021

Armenia

Switzerland and Armenia signed tax treaty protocol November 12, reducing dividend tax rate and implementing standards on treaty abuse, mutual agreement procedure, and exchange of information: Switzerland SIF→

November 18, 2021

Multinational

United Nations tax body is needed to address cross-border tax abuse and reform global tax regulations; OECD deal gave developing countries a voice but didn’t listen: José Antonio Ocampo / Project Syndicate→

November 17, 2021

Americas

US corporate minimum tax proposal would likely hit several large companies in tech (Amazon, Google, Intel), telecom (Verizon, Comcast), banking (Morgan Stanley, JPMorgan Chase), and more: Kevin Schaul / Washington Post→

November 8, 2021

Africa

Kenya prefers its digital tax, which hits 89 companies in the country, to global tax deal, which would only hit 11 (exempting Uber and others); also objects, with Nigeria, to deal’s mandatory binding arbitration: Carlos Mureithi / Quartz Africa→

November 5, 2021

Americas

US corporate income tax receipts for fiscal year 2021 were above budget estimates by USD 103 billion (or about 38%) – with significantly higher receipts than expected attributed to ‘improved economy’: U.S. Department of Treasury→

October 22, 2021

Asia-Pacific

Pakistan reportedly will be out an extra USD 150 million in tax revenues annually if it stays outside global tax deal, according to OECD estimates: Mehtab Haider / The News→

October 21, 2021

Americas

Bermuda’s tax advantage in (re)insurance industry will diminish under global minimum tax, which will reduce, but not eliminate, gap in effective tax rate between Bermuda and non-Bermuda companies: Fitch Ratings→

October 20, 2021

Africa

Kenya contends revenue threshold for companies subject to Pillar 1 of OECD agreement is too high, lower threshold is needed for developing countries to benefit: Kenya Revenue Authority→

October 20, 2021

Estonia

Estonia’s joining global tax deal may mean some companies will look elsewhere, but there will be no mass exodus, and Estonian companies could have been worse off outside deal, Finance Ministry predicts: Baltic Times→

October 19, 2021

Americas

US Democrats consider delaying until 2023 hike in global intangible low-taxed income (GILTI) rate, and possibly only increasing to 15%, to align with OECD agreement, appease moderates: Laura Weiss / Roll Call→

October 15, 2021

Multinational

Global tax pact’s ‘revolution’ builds on old concepts – long-standing apportionment rules between US states in case of Pillar 1 and century-old ‘single tax principle’ in case of Pillar 2: Reuven Avi-Yonah / LinkedIn→

October 12, 2021

Multinational

OECD tax deal compromise did not deliver all that many wanted, but it still represents several ‘major steps forward’ and was probably ‘as good a deal’ as the OECD – or the UN – could have got: Richard Murphy / Tax Research UK→

October 11, 2021

Europe

Greek bill would cut corporate income tax rate by 30% for three years for mergers between small- and medium-sized enterprises: Eirini Chysolora / eKathimerini→

October 4, 2021

Africa

Multilateral convention to implement tax treaty related measures to prevent BEPS gains 96th signatory in Namibia, will enter into force for Andorra and Spain in January 2022: OECD→

September 30, 2021

Europe

Ireland reportedly ready to increase corporate tax rate to 15% if OECD agrees to strike from agreement term that global minimum tax be ‘at least’ 15%: Pat Leahy & Cormac McQuinn / Irish Times→

September 27, 2021

Europe

American Chamber of Commerce in Ireland advises Irish Finance Minister that it’s not in country’s interests to resist a global minimum tax agreement: Arthur Beesley & Naomi O’Leary / Irish Times→

September 20, 2021

RECENT COMMENTS

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
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

Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.