Multinational

Profs’ “Pillar 2” proposal advocates minimum effective taxation at 10–12.5 % rate with subs’ ETR figured using international accounting rules, undertaxed payments rule would complement: Johannes Becker & Joachim Englisch / SSRN→

April 16, 2019

Featured News

The UN transfer pricing manual’s new chapter on financial transactions: the details

April 15, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, offer a detailed analysis of the UN Committee of Experts on International Cooperation in Tax Matters’ April 8 a draft chapter on financial transactions, proposed as an update to the UN Practical Manual on Transfer Pricing for Developing Countries . . .

Digital Economy

France won’t replace digital tax unless OECD solution captures value of data, Le Maire says: Isabel Gottlieb / Bloomberg Tax→

April 14, 2019

Featured News

UN tax committee releases draft transfer pricing chapter on financial transactions, other docs ahead of meeting (Updated)

April 10, 2019

The UN has released draft updates to the United Nations Practical Manual on Transfer Pricing for Developing Countries — including a key chapter on financial transactions — and more . . .

Europe

BEPS MLI to alter Luxembourg tax treaties as of August 1

April 9, 2019

Luxembourg today deposited its instrument of ratification for the . . .

Americas

CIAT preparing “sixth method” transfer pricing database

April 9, 2019

Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium discuss CIAT’s new transfer pricing database for use in applying the sixth method . . .

Featured News

UN tax committee releases proposed updates to model tax treaty in advance of meeting

April 3, 2019

The UN today released six documents in advance of the eighteenth session of the UN Committee of Experts on International Cooperation in Tax Matter, to be held April 23–26 in New York. The documents, written by . . .

Americas

CIAT-SECO partnership strengthens Latin American and Caribbean tax administrations

April 3, 2019

Robert Feinschreiber of Charles River Associates and Margaret Kent of Transfer Pricing Consortium, discuss recent activities of the Inter-American Center of Tax Administrations (CIAT) and the State Secretariat for Economic Affairs of the Swiss Government (SECO) to assist tax administrations in Bolivia, El Salvador, Guatemala, Guyana, Honduras, and Nicaragua with transfer pricing and other issues . . .

Europe

Netherlands deposits MLI ratification instrument with OECD after opting out of PE rule

April 1, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. note that the Netherlands on March 29 deposited its instrument of ratification of the BEPS MLI with the OECD and discuss the clauses that the Netherlands opted to adopt . . .

Asia-Pacific

Multilateral tax treaty enters into force in Singapore affecting 14 bilateral treaties

April 1, 2019

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) entered . . .

Digital Economy

Professors advocate “Residual Profit Allocation by Income” (RPA-I), giving market countries the right to tax residual profit using either of two suggested approaches: Michael P. Devereux, Alan Auerbach, Michael Keen, Paul Oosterhuis, Wolfgang Schön & John Vella / SSRN→

April 1, 2019

Featured News

Tax officials from 46 countries agree to expand ICAP pilot, improve transfer pricing administration

March 29, 2019

TThe OECD Forum on Tax Administration on March 29 announced their support for . . .

Part two: international tax consultation on “digitalization” draws 50 speakers (pillar two)

March 26, 2019

Part two of two. This article summarizes discussion of the “pillar two” proposals at the OECD digitalization consultation, held March 13–14 in Paris. The pillar two proposals, described in a February 13 OECD discussion draft, call for global adoption of a minimum tax and a tax on base eroding payments. . . .

International Monetary Fund

IFM Chief advocates “fundamental rethink of international taxation,” says current system is unfair, out of date, and harms low-income countries: International Monetary Fund→

March 26, 2019

Featured News

Countries approve OECD proposal on VAT/GST collection by digital platforms

March 25, 2019

MNE Tax contributing editor, Davide Anghileri of the University of Lausanne, discusses the fifth Global Forum on VAT meeting in Melbourne, held March 20-22, where more than 100 jurisdictions, endorsed an OECD report on the role of digital platforms in the collection of VAT/GST on online sales . . ..

Vodafone voluntarily publishes country-by-country report: Vodafone→

March 25, 2019

Digital Economy

Part one: OECD tax consultation on digitalization features 50+ speakers, diverse viewpoints (pillar one)

March 21, 2019

More than 50 international tax and transfer pricing experts from business, academia, labor, and non-governmental organizations spoke at a March 13–14 consultation, held at the OECD in Paris, on the tax challenges of digitalization. This article addresses the first day of the consultation which concerned the “pillar one” policy proposals . . .

Featured News

First Look: OECD holds consultation on digitalization of the economy

March 14, 2019

The OECD held a public hearing today and yesterday on possible solutions to the tax challenges . . .

International Monetary Fund

IMF paper proposes criteria for assessing international tax reform proposals: International Monetary Fund→

March 12, 2019

Featured News

OECD releases 200+ comment letters responding to key international tax consultation

March 8, 2019

The OECD today released more than 200 comment letters received in response to a public consultation which, while said to be focused on “the tax challenges of the digitization of the economy,” has morphed into . . .

Digital Economy

11 political science academics join to comment on digitalization consultation, address global cooperation in taxation→

March 7, 2019

Denmark

EU court issues landmark decision on Member State power to deny tax benefits

February 27, 2019

Jian-Cheng Ku and Rhys Bane of DLA Piper Nederland N.V. discuss a February 26 European Court of Justice decision which concerns when EU Member States can deny tax benefits granted under the Parent-Subsidiary Directive or the Interest and Royalty Directive when fraud or abuse is involved . . .

More News

Van Hove is new head of OECD tax treaties, transfer pricing, financial transactions division

February 27, 2019

Jeffrey Van Hove is the new Head of the Tax Treaty, Transfer Pricing and Financial Transactions Division a the . . .

Multinational

To end profit shifting, MNEs should be taxed in location of sale, UC Berkeley prof. argues: Gabriel Zucman / Economists for Inclusive Prosperity→

February 26, 2019

Africa

New CIAT database tracks BEPS implementation in 36 countries

February 22, 2019

The Inter-American Center of Tax Administrations (CIAT) on February 21 released . . .

Americas

US FDII rules under review as potentially harmful tax regime, Treasury official says

February 19, 2019

The US’s foreign-derived intangibles income (FDII) tax rules are being scrutinized by the OECD’s Forum on Harmful Tax. . .

Americas

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

February 19, 2019

The OECD today asked multinational taxpayers and their advisors to provide information about their experiences with the tax treaty . . .

Featured News

OECD extends comment deadline for international tax consultation on digitalization

February 19, 2019

The OECD today announced that the deadline to provide public . . .

Multinational

Authors analyze OECD draft transfer pricing rules for intragroup financial guarantees: Vera Averyanova & Vikram Chand / Kluwer International Tax Blog→

February 15, 2019

Featured News

OECD report shows countries’ progress shutting down tax treaty shopping

February 14, 2019

The OECD today released a report assessing whether 116 countries are following . . .

Featured News

OECD seeks public input on proposals addressing tax challenges of digital economy

February 13, 2019

The OECD today invited the public to provide input on proposals to modify the existing international tax rules in a coordinated way. . .

Europe

Guernsey ratifies multilateral tax treaty aimed at closing MNE tax loopholes

February 12, 2019

Today, Guernsey became the 20th jurisdiction to deposit with the OECD its instrument of ratification for . . .

Asia-Pacific

Japan-Ireland tax treaty to be modified by MLI

February 11, 2019

The Japanese government on February 8 announced that a 1974 bilateral tax treaty between Japan and Ireland . . .

Armenia

Armenia joins “Inclusive Framework on BEPS” to fight MNE tax avoidance

February 11, 2019

Armenia has joined the “Inclusive Framework on BEPS,” an OECD-led coalition of countries . . .

Americas

Countries won’t abandon arm’s length principle in global tax overhaul, US official says

February 2, 2019

Despite language in a recent “Inclusive Framework on BEPS” policy note, there is little chance that countries working to update the rules governing the allocation of taxing rights . . .

Africa

Assessment of “harmful” tax regimes released, inquiry moves to low-tax jurisdictions

January 31, 2019

The OECD has published a progress report detailing whether countries are meeting their commitments to . . .

Americas

April 23--26	Eighteenth Session of the UN Committee of Experts on International Cooperation in Tax Matters	New York, NY USA
April 29	UN ECOSOC special Meeting on “International Cooperation in Tax Matters”	New York, NY USA
May 9-11	American Bar Association May Tax Meeting	Washington, DC USA
May 16--17	National Tax Association - Spring Symposium - Certain Uncertainty: Tax Plicy in Unsettled Times	Washington, DC USA
June 8--9	G20 Finance Ministers and Central Bank Governors meeting	Fukuoka, Japan

Multinational

Profs’ “Pillar 2” proposal advocates minimum effective taxation at 10–12.5 % rate with subs’ ETR figured using international accounting rules, undertaxed payments rule would complement: Johannes Becker & Joachim Englisch / SSRN→

The UN transfer pricing manual’s new chapter on financial transactions: the details

France won’t replace digital tax unless OECD solution captures value of data, Le Maire says: Isabel Gottlieb / Bloomberg Tax→

UN tax committee releases draft transfer pricing chapter on financial transactions, other docs ahead of meeting (Updated)

BEPS MLI to alter Luxembourg tax treaties as of August 1

CIAT preparing “sixth method” transfer pricing database

UN tax committee releases proposed updates to model tax treaty in advance of meeting

CIAT-SECO partnership strengthens Latin American and Caribbean tax administrations

Netherlands deposits MLI ratification instrument with OECD after opting out of PE rule

Multilateral tax treaty enters into force in Singapore affecting 14 bilateral treaties

Professors advocate “Residual Profit Allocation by Income” (RPA-I), giving market countries the right to tax residual profit using either of two suggested approaches: Michael P. Devereux, Alan Auerbach, Michael Keen, Paul Oosterhuis, Wolfgang Schön & John Vella / SSRN→

Tax officials from 46 countries agree to expand ICAP pilot, improve transfer pricing administration

Part two: international tax consultation on “digitalization” draws 50 speakers (pillar two)

IFM Chief advocates “fundamental rethink of international taxation,” says current system is unfair, out of date, and harms low-income countries: International Monetary Fund→

Countries approve OECD proposal on VAT/GST collection by digital platforms

Vodafone voluntarily publishes country-by-country report: Vodafone→

Part one: OECD tax consultation on digitalization features 50+ speakers, diverse viewpoints (pillar one)

First Look: OECD holds consultation on digitalization of the economy

IMF paper proposes criteria for assessing international tax reform proposals: International Monetary Fund→

OECD releases 200+ comment letters responding to key international tax consultation

11 political science academics join to comment on digitalization consultation, address global cooperation in taxation→

EU court issues landmark decision on Member State power to deny tax benefits

Van Hove is new head of OECD tax treaties, transfer pricing, financial transactions division

To end profit shifting, MNEs should be taxed in location of sale, UC Berkeley prof. argues: Gabriel Zucman / Economists for Inclusive Prosperity→

New CIAT database tracks BEPS implementation in 36 countries

US FDII rules under review as potentially harmful tax regime, Treasury official says

MNEs asked to assess tax treaty MAP in Guernsey, Isle of Man, Jersey, Monaco, San Marino, Serbia, Brunei, Curaçao

OECD extends comment deadline for international tax consultation on digitalization

Authors analyze OECD draft transfer pricing rules for intragroup financial guarantees: Vera Averyanova & Vikram Chand / Kluwer International Tax Blog→

OECD report shows countries’ progress shutting down tax treaty shopping

OECD seeks public input on proposals addressing tax challenges of digital economy

Guernsey ratifies multilateral tax treaty aimed at closing MNE tax loopholes

Japan-Ireland tax treaty to be modified by MLI

Armenia joins “Inclusive Framework on BEPS” to fight MNE tax avoidance

Countries won’t abandon arm’s length principle in global tax overhaul, US official says

Assessment of “harmful” tax regimes released, inquiry moves to low-tax jurisdictions

Barbados receives confirmation that OECD no longer views tax regime as harmful: tv6tnt.com→

Tax advisory work grew by 8.6% globally in 2017 hitting record GBP 15.4bn (USD 20.2bn): Economia→

Ireland ratifies BEPS MLI to fight MNE tax avoidance