Africa
Multinational
Americas
Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
Alex M. Parker, Capitol Counsel LLC, discusses why last year’s OECD-G20 global minimum tax agreement has revealed a scope much broader than most anticipated; provisions of the agreement, revealed in technical commentary released by the OECD in the past months, could affect everything from green energy incentives to affordable housing credits in the U.S.
Accounting
Americas
Americas
Africa
G20
Americas
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International Monetary Fund
Americas
Biden’s tax reforms could leave US multinational corporations at a competitive disadvantage
Kyle Pomerleau, American Enterprise Institute, warns that while the Biden Administration’s recently released 2023 budget—which includes additional reforms to the tax treatment of multinational corporations—is intended to further align the U.S. tax code with the OECD’s Pillar Two model rules and enhance the competitiveness of U.S. multinational corporations, they actually could leave U.S. companies at a competitive disadvantage.
Americas
Interest on inbound financing: is it arm’s length?
Annemarie Wilmore, Johnson Winter & Slattery, discusses the latest developments in the Australian case of Singapore Telecom Australia Investments Pty Ltd v Commissioner of Taxation when the Australian Federal Court issued a further decision on March 22, including its consideration of whether consequential adjustments to the transfer pricing benefit should be made to take into account carryforward losses.
Estonia
Asia-Pacific
Austria
Europe
Asia-Pacific
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Asia-Pacific
Belgium
The year 2022 brings new wave of transfer pricing audits to MNEs in Belgium
Aldo Engels, Loyens & Loeff, discusses the Belgian government’s recent decision to increase the effectiveness of transfer pricing audits of MNEs—followed by a new wave of transfer pricing audits initiated in the beginning of 2022—and provides an overview of recent trends in the Belgian transfer pricing audit practice.
Asia-Pacific
Digital Economy
Americas
Why Pillar Two should be abandoned
Allan Lanthier, a former advisor to the Canadian government, argues that when EU finance ministers next meet on April 5, they should abandon Pillar Two, which, he says, is a deeply flawed initiative that includes major changes on which countries had never previously agreed, including a new Domestic Minimum Top-Up tax and a significant rewrite of the Undertaxed Payment Rule.
Americas
Asia-Pacific
Significant changes to the income tax treaty between Austria and the UAE as of 2023
Iris Burgstaller and Fanni Deak, TPA Austria, discuss recent changes to the Austria-United Arab Emirates income tax treaty to implement the OECD standards on base erosion and profit shifting (BEPS); after the exchange of the instruments of ratification, the amendments will be applicable for tax years after December 31, 2022.
Europe
Asia-Pacific
Europe
G20
Asia-Pacific
Accounting
Europe
Switzerland likely to change its constitution because of Pillar Two global minimum tax plan
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.
Estonia
Asia-Pacific
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G20
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Americas
Americas
The Pillar Two model rules: a train wreck in the making
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.
