G20–MNE Tax

G20

OECD seeks public comments by April 29 on extractives exclusion under Amount A of Pillar One. The extractives exclusion will exclude from the scope of Amount A the profits from extractive activities: OECD→

April 14, 2022

Asia-Pacific

Thailand extends deadlines for filing transfer pricing disclosure forms and reports

April 5, 2022

Paul Ashburn, HLB Thailand, discusses the Thailand Ministry of Finance’s March 25 extension of the deadline to May 30, 2022 for companies to file related-party disclosure forms for the accounting period(s) that began between January 1, 2020 to December 31, 2020.

Asia-Pacific

Australian transfer pricing: what multinational groups need to know

March 31, 2022

Geoff Morris, InTP, provides an overview of Australia’s transfer pricing laws and the tax administration’s practices in this area, focusing on the provisions, as well as on how Australia monitors transfer pricing risks.

Americas

Why Pillar Two should be abandoned

March 28, 2022

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.

G20

OECD releases latest peer review assessing the actions jurisdictions have taken to prevent tax treaty shopping, other forms of treaty abuse under Action 6 of the OECD/G20 BEPS project: OECD→

March 21, 2022

Asia-Pacific

Jordan publishes formal transfer pricing compliance forms

March 17, 2022

Nour Ali, DNV, discusses the Jordanian Income and Sales Tax Department’s publication in early March of formal transfer pricing compliance forms over a dedicated transfer pricing platform on its official website.

G20

The OECD/G20 Inclusive Framework on BEPS invites public comments on Pillar Two by April 11: OECD→

March 14, 2022

Europe

International taxation: two-pillar plan and the OECD mainstream

February 28, 2022

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses the February 21 virtual “OECD Tax Talks” webinar to assess the world’s progress in implementing the historic OECD/G20 two-pillar international tax package.

Europe

Spain’s annual guidelines on tax and customs controls focus on transfer pricing issues

February 28, 2022

Abigail Blanco Vázquez and Mario Ortega, J&A Garrigues, S.L.P., discuss the Spanish tax agency’s January 31 publication of the general guidelines of the 2022 Annual Tax and Customs Control Plan, containing transfer pricing changes, including a new automated transfer pricing risk analysis system.

Africa

Kenya: embracing the two-pillar approach

February 23, 2022

Samuel Okumu, Rödl & Partner Limited, discusses the OECD-Kenya Revenue Authority’s three-day workshop in Naivasha, Kenya in late January to assess Kenya’s efforts in enacting the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS).

OECD launches public consultation on Pillar One draft model rules on revenue sourcing and nexus

February 10, 2022

Nyasha Nigel Machiri, HLB Zambia, discusses the OECD announcement that it is seeking public comment by February 18 on recently released draft model rules with respect to nexus and revenue sourcing under Amount A of Pillar One as part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the two-pillar solution.

Africa

International tax-related information exchange generates billions in revenue, Global Forum reports

November 17, 2021

The automatic exchange of financial account information between countries is linked directly to at least EUR 3 billion in additional tax revenues; it also has contributed, through voluntary disclosure and other programs, to more than EUR 112 billion in additional tax revenues, according to a November 17 . . .

Europe

Irish Finance Minister outlines reasoning in joining global tax deal

November 10, 2021

The benefits to Ireland of joining the OECD/G20 global tax deal “far outweigh” the downsides of remaining outside the deal, which would carry “very real risks,” Irish Finance Minister Paschal Donohoe explained in a November 10 address to . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Developing countries need transfer pricing rule simplifications, OECD advises G20

October 18, 2021

The OECD highlights the importance for developing countries of streamlining complex transfer pricing rules and facilitating access to country-by-country reports in October 13 recommendations to . . .

Africa

Global tax talks reach ‘critical mass’ for landmark deal by tweaking details

October 8, 2021

The historic October 8 agreement on a global minimum tax and new rules for allocating taxing rights for large multinationals both firms up issues left open in the initial July statement and reflects concessions that were made to bring into the deal a few new countries, including . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Americas

OECD’s GloBE rules: Blending in with jurisdictional blending

September 24, 2021

Noopur Trivedi and Jitesh Golani, international tax researchers, discuss how – out of the multiple design elements of the global minimum tax in the OECD/G20 July 1 statement – the adoption of “jurisdictional blending” for computation of effective tax rate, and consequent top-up tax, is one of the most pivotal . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Estonia

EU state of the union address calls for tax reforms

September 17, 2021

European Commission President Ursula von der Leyen stressed the importance of fair taxation and initiatives to expand the tax base in her 2021 state of the union address on September 15, emphasizing . . .

Europe

Ireland 2022 budget strategy papers address corporate, international tax policies

September 16, 2021

The Irish Department of Finance on September 16 published a series of papers examining tax policy in advance of Budget 2022, including issues related to corporate tax and international . . .

Americas

Asia to see disparate impacts from global digital tax reforms, IMF reports

September 15, 2021

Global tax reform efforts to address digitalization of the economy would likely have modest revenue effects in Asia, on the whole, according to a September 14 report from the International Monetary Fund; however, the effects would be uneven . . .

Europe

Corporate tax rates down 10 percentage points among OECD, G20, EU countries

September 9, 2021

The combined statutory corporate income tax rates among OECD, G20, and EU countries dropped in parallel from 2000–2021, 10 percentage points in each group, while broadly maintaining their positions relative to each other, according to a September 8 OECD tax . . .

Americas

US Senate unveils international tax reform draft legislation

August 25, 2021

Senate Finance Committee Chairman Ron Wyden (D-Ore.) on August 25 released draft legislation for international tax reform that would retain but modify key provisions of the Republicans’ 2017 tax law, including the global intangible low-taxed income (GILTI) provision, foreign-derived intangible income (FDII), and . . .

Americas

Japan releases study group report on international taxation in the digital economy

August 19, 2021

Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .

Asia-Pacific

Gulf Cooperation Council countries and businesses prepare for global minimum tax

August 16, 2021

Raman Ohri, Keypoint, discusses the dilemma that the July 1 inclusive framework agreement on a global minimum tax created for Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates . . .

Americas

Global minimum tax could create confusion with current CFC rules

July 28, 2021

Thomas Locher, Tax Foundation’s Center for Global Tax Policy, discusses how the implementation of a global minimum tax could create confusion with current CFC rules, raising questions about . . .

Americas

EU continues to wrangle over global minimum tax’s carve-outs, rate

July 26, 2021

A July 21 study from the EU Tax Observatory predicts that a substance carve-out under the agreement for a proposed global minimum tax could exacerbate tax competition and would reduce by 15% to 30% the tax revenues that the EU would otherwise . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

July 6, 2021

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

Americas

US tells EU countries digital levy could jeopardize global tax talks

July 1, 2021

The Biden Administration has been reaching out to several European countries, according to June 30 reports, asking them to press the European Commission to put off a digital levy proposal that could. . .

Digital Economy

G7 global minimum tax deal leaves open questions

June 30, 2021

Vasiliki Koukoulioti, PhD researcher at Queen Mary University of London, discusses the questions that still surround the details of the global minimum tax agreement that G7 finance ministers reached on June 5 . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

June 16, 2021

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Europe

EU will propose minimum tax legislation if G20 reaches deal, commissioner says

June 14, 2021

The European Commission will propose legislation to implement an international agreement on a global minimum corporate tax to ensure its uniform application within the EU, according to June 14 . . .

Europe

Ukraine implements mutual agreement procedure for resolving tax disputes

June 10, 2021

Viktoriia Bublichenko, GOLAW, discusses the Ukraine finance ministry’s March 26 decree establishing the detailed order of conduct of the mutual agreement procedure (MAP) for resolving international tax disputes . . .

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

June 7, 2021

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

Americas

G7 reportedly close to deal on new rules for taxing multinationals

May 24, 2021

The G7 group of leading economies is getting close to an agreement to shake up the global rules on the taxation of multinational businesses . . .

Europe

Ukraine tax authorities adopt new rules for nonresident registration

May 7, 2021

Iryna Kalnytska, GOLAW, discusses Ukrainian tax guidance concerning foreign (non-resident) companies that must register with Ukrainian tax authorities . . .

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

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin