What We're Reading–MNE Tax

Multinational

Global minimum tax agreement’s terms – including optional adoption, a substance carve-out, and a rate as low as 15% – mean it may not be robust, strict, and widely-enough adopted to be effective: Michael P. Devereux & John Vella / Oxford University Centre for Business→

Europe

Ireland will likely give up its 12.5% corporate tax rate later this year in response to OECD tax agreement impetus, Irish government officials reportedly suggest: Daniel McConnell / Irish Examiner→

OECD

Yellen predicts US businesses will press Congress to approve global corporate tax overhaul plans because of the tax certainty such an agreement would offer: Christopher Condon / Accounting Today→

Asia-Pacific

Hong Kong will implement international consensus on BEPS 2.0 while striving to maintain tax advantages in terms of simplicity, certainty, and fairness: Hong Kong Inland Revenue Department→

Americas

Latin America tax transparency report finds region committed to tackling tax evasion through implementing tax information exchange standards, but the tools are not yet widely used: OECD→

Multinational

OECD ‘brochure’ touts two-pillar international tax reform plan as solution to estimated USD 100-240 billion in revenues that countries worldwide lose annually to corporate tax avoidance: OECD→

Americas

US Republican lawmakers send Treasury Secretary Yellen letter pressing for harder stance in favor of pro-US terms in international tax negotiations: Senator Mike Crapo (R-Idaho) and Congressman Kevin Brady (R-Texas)→

Europe

Luxembourg government contests press reports about tax authorities accepting as binding informal tax rulings authored by taxpayers or their advisors: Luxembourg Ministry of Finance→

Africa

African Tax Administration Forum welcomes July 1 consensus on international tax reform as including important developments for African countries but cautions against coercing developing countries: ATAF→

Europe

EU digital levy to be proposed July 20 will consist of 0.3% tax on goods and services sold online by companies in EU with turnover of at least EUR 50 million (USD 59 million): Bjarke Smith-Meyer / Politico→

Asia-Pacific

UK-based Cairn Energy garners court order in France to seize Indian government property valued at more than EUR 20 million in enforcement of international arbitration award: Tribune India→

Asia-Pacific

Taiwan Ministry of Finance reminds businesses claiming foreign tax credits to ensure foreign tax liability should not have been reduced or exempted under applicable tax treaty: R.O.C. Ministry of Finance→

Americas

US bill introduced in House to zero out base erosion and anti-abuse tax (BEAT) liability temporarily for 2020 as pandemic relief: Congressman Andy Kim (D-NJ)→

Americas

US IRS ‘practice unit’ explains rules applicable to foreign tax redeterminations when a change in a taxpayer’s foreign tax liability affects previously claimed foreign tax credits: Internal Revenue Service→

Americas

US Treasury Secretary stresses importance of India’s support for ‘robust global minimum tax’ in call with Indian Finance Minister: U.S. Treasury→

Americas

Argentina’s Economy Minister says 15% rate for global minimum corporate tax is too low, seeks rate of 21%–25%: Buenos Aires Times→

Europe

EU’s new VAT rules on online shopping enter into force July 1, affecting online sellers and platforms located both in and outside the EU: European Commission→

Europe

European tax study confirms slow downward trend in corporate tax rates in EU, with both average top and effective corporate tax rates falling 1.5 percentage points over last decade to 21.4% and 19.2%, respectively: European Commission→

Philippines

Philippines to be removed from OECD harmful tax regimes list in January 2022 following enactment of legislation eliminating preferential tax rates for regional operating headquarters: Philippines Department of Finance→

Antigua and Barbuda

Antigua and Barbuda, Argentina, Russia, South Africa, and Ukraine make progress on meeting international standard on tax transparency and exchange of information in latest peer reviews: OECD→

Multinational

Tax complexity for multinational corporations continues to increase, with transfer pricing presenting greatest complexity due to intricate documentation requirements and ambiguous rules, according to new global survey: Accounting for Transparency→

United States

US corporations pay lower effective tax rate than their foreign competitors and would likely continue to under proposed Biden corporate tax rate increase, according to Reuters analysis: Tom Bergin (Reuters) / Nasdaq→

Americas

New OECD toolkit guides Latin American and Caribbean tax authorities on applying value-added tax to e-commerce activities: OECD→

Canada

Canada updates guidance on competent authority procedures for taxpayers trying to resolve issues relating to double taxation or taxation not in accordance with an applicable tax treaty: Canada Revenue Agency→

Georgia

Japan–Georgia tax treaty signed January 29 will enter into force on July 23 following June 23 exchange of diplomatic notes: Japan Ministry of Finance→

Europe

EU consults on plan to tackle debt-equity bias in corporate taxation through measures aimed at equalizing tax treatment of debt and equity to be combined with accompanying anti-abuse provisions: European Commission→

China

China may not have much to lose under global corporate minimum tax and could hinge its support on US’s willingness to lift tariffs on Chinese goods: Frank Tang / South China Morning Post→

Ireland

Ireland will seek yet-to-be-defined compromise in global minimum tax talks with aim of preserving room for tax competition by smaller countries, Irish Finance Minster says: Silvia Amaro / CNBC→

United States

US IRS internal training document explains application of global intangible low-taxed income (GILTI) rules, including scope, computation, and allocation: Internal Revenue Service→

Mexico

Mexican Finance Secretary and US Treasury Secretary discuss importance of Mexico’s support within G20 for global minimum tax: U.S. Department of Treasury→

United States

US government bipartisan study on corporate tax reform finds that economic distortions caused by corporate taxes have declined over time and could be further reduced by additional changes: Congressional Research Service→

Europe

EU customs regulations will require payment of import turnover tax on goods valued under EUR 22 starting July 1: Austrian Ministry of Finance→

United States

US House passes bill to require public country-by-country reporting by SEC-registered multinational corporations: FACT Coalition→

Asia-Pacific

Singapore updates tax guidance for advertising industry: Inland Revenue of Singapore→

Europe

Royalty payments from Ireland to US jumped from about EUR 8 billion (USD 9.6 billion) annually to EUR 52 billion (USD 62.5 billion) in 2020, concludes report published on Irish government website: Seamus Coffey / University College Cork→

Europe

Two EU Parliament committees approve public country-by-country compromise: European Interest→

Germany

Indonesian, Mexican, South African finance ministers join German, US counterparts in op-ed endorsing global minimum tax of at least 15%: Arturo Herrera Gutiérrez, Sri Mulyani Indrawati, Tito Mboweni, Olaf Scholz and Janet L. Yellen / Washington Post→

OECD

UK finance minister Rishi Sunak seeks agreement on financial services exemption from global minimum tax: Emma Agyemang, George Parker, Chris Giles / Irish Times→

Digital Economy

Professor says source taxation of nonresident digital businesses is justified because value creation is partly derived from infrastructure and other benefits provided by market jurisdiction: Craig Elliffe / SSRN→

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