Multinational

Digital Economy

Professors discuss rational, advantages, and problems of pillar 2 GLOBE proposal: Joachim Englisch & Johannes Becker / SSRN→

June 10, 2019

Multinational

Professor offers alternatives to OECD’s “questionable” hybrid entity mismatch approach: Leopoldo Parada / SSRN→

June 10, 2019

Digital Economy

G20 finance ministers endorse Inclusive Framework’s work plan for international tax reboot

June 9, 2019

G20 finance ministers and central bank governors at their June 8–9 meeting in Tsukuba, Japan, endorsed a work plan developed by a 129-country coalition called the “Inclusive Framework on BEPS” which provides . . .

Americas

Agreement reached on OECD transfer pricing guidelines for financial transactions, official says

June 8, 2019

Countries working on new OECD transfer pricing guidelines for financial transactions have reached agreement on virtually all issues associated with the project, The OECD’s Thomas Balco said June 4 at the 2019 OECD International Tax Conference. Balco also provided an update on other OECD transfer pricing projects, including the 2020 review of the country-by-country . . .

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OECD study suggests automatic exchange of information reduced bank deposits in offshore financial centers

June 7, 2019

Preliminary findings of an upcoming OECD study show that automatic exchange of information has reduced cross-border bank deposits in 46 international . . .

Asia-Pacific

MLI to enter into force for United Arab Emirates

June 6, 2019

The United Arab Emirates deposited its instrument of . . .

Asia-Pacific

Singapore’s tax treaties with Finland and Guernsey amended by MLI

June 3, 2019

The Inland Revenue Authority of Singapore (IRAS) has announced that amendments to . . .

Featured News

OECD publishes work plan for sweeping international tax reform

May 31, 2019

As expected, the OECD today published a work plan setting out a process for reaching global consensus on revised rules for taxing multinationals. This key document had been agreed to by the 129-country . . .

Featured News

129-country coalition agrees to work plan to develop new international tax and transfer pricing rules

May 28, 2019

The BEPS Inclusive Framework today agreed to a work plan to develop international tax and transfer pricing rules that address the problems . . .

Asia-Pacific

Synthesized text of Australia-Singapore tax treaty published: Australian Taxation Office→

May 25, 2019

Digital Economy

International tax rules should recognize value creation from scale, brands, market access, Irish Minister says: Reuters→

May 23, 2019

Americas

Cayman Island guidance released on economic substance

May 16, 2019

The Cayman Islands government on April 30 . . .

Multinational

Prof offers alternatives to OECD approach to hybrid entity mismatches: Leopoldo Parada / SSRN→

May 16, 2019

Europe

Ireland should “engage constructively” on digitalization, tax avoidance to safeguard reputation, IMF says: International Monetary Fund→

May 14, 2019

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UN publishes tax committee working methods and practices

May 7, 2019

The UN today published a document outlining the practices and working methods . . .

Asia-Pacific

Singapore-Ireland tax treaty MLI amendments enter into effect

May 2, 2019

The Singapore government has announced that amendments made to the Singapore-Ireland tax treaty as a result of . . .

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OECD releases 2017 model tax treaty

April 24, 2019

The OECD today released the full version of the 2017 edition of the OECD Model Tax Convention . . .

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 . . .

June 28--29	G20 Leaders meeting	Japan
July 16--17	NABE Transfer Pricing Symposium 2019	Washington, DC USA